NIST OWM Analysis

2022 NCWM Annual S&T Agenda Items

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NIST Office of Weights and Measures (OWM) Analysis 

Specifications and Tolerances (S&T) 

2022 NCWM Annual Meeting Agenda 

The NIST OWM Analysis is submitted to the assist the Weights and Measures community as it deliberates 

on items before the Conference. OWM offers these comments and recommendations based upon 

information and input available as of the date of this report. 

Language shown in bold face print by striking out information to be deleted and underlining information 

to be added. Requirements that are proposed to be nonretroactive are printed in bold faced italics. 

For additional information or assistance please contact an OWM Technical Advisor: 

Mrs. Tina Butcher, S&T Committee, tina.butcher@nist.gov or (301) 975-2196

Mr. Rick Harshman, S&T Committee, richard.harshman@nist.gov or (301) 975-8107

Mr. Jan Konijnenburg, NIST Associate, jan.konijnenburg@nist.gov 

Ms. Diane Lee, S&T Committee, diane.lee@nist.gov or (301) 975-4405

Ms. Juana Williams, S&T Committee, juana.williams@nist.gov or (301) 975-3989
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Subject Series List for the Specifications and Tolerances Committee

Handbook 44 – General Code...................................................................................................... GEN Series

Scales...................................................................................................................................... SCL Series

Belt-Conveyor Scale Systems ................................................................................................BCS Series

Automatic Bulk Weighing Systems ..................................................................................... ABW Series

Weights.................................................................................................................................. WTS Series

Automatic Weighing Systems...............................................................................................AWS Series

Weigh-In-Motion Systems used for Vehicle Enforcement Screening ..................................WIM Series

Liquid-Measuring Devices....................................................................................................LMD Series

Vehicle-Tank Meters.............................................................................................................VTM Series

Liquefied Petroleum Gas and Anhydrous Ammonia Liquid-Measuring Devices..................LPG Series

Hydrocarbon Gas Vapor-Measuring Devices........................................................................HGV Series

Cryogenic Liquid-Measuring Devices ..................................................................................CLM Series

Milk Meters...........................................................................................................................MLK Series

Water Meters.........................................................................................................................WTR Series

Mass Flow Meters................................................................................................................ MFM Series

Carbon Dioxide Liquid-Measuring Devices.......................................................................... CDL Series

Hydrogen Gas-Metering Devices......................................................................................... HGM Series

Electric Vehicle Refueling Systems.......................................................................................EVF Series

Vehicle Tanks Used as Measures.......................................................................................... VTU Series

Liquid Measures....................................................................................................................LQM Series

Farm Milk Tanks................................................................................................................... FMT Series

Measure-Containers...............................................................................................................MRC Series

Graduates............................................................................................................................... GDT Series

Dry Measures ........................................................................................................................ DRY Series

Berry Baskets and Boxes....................................................................................................... BBB Series

Fabric-Measuring Devices......................................................................................................FAB Series

Wire-and Cordage-Measuring Devices................................................................................ WAC Series

Linear Measures......................................................................................................................LIN Series

Odometers .............................................................................................................................ODO Series

Taximeters...............................................................................................................................TXI Series

Timing Devices ...................................................................................................................... TIM Series

Grain Moisture Meters (a).................................................................................................... GMA Series

Grain Moisture Meters (b).................................................................................................... GMB Series

Near-Infrared Grain Analyzers................................................................................................NIR Series

Multiple Dimension Measuring Devices............................................................................. MDM Series

Electronic Livestock, Meat, and Poultry Evaluation Systems and/or Devices.......................LVS Series

Transportation Network Measuring Systems.........................................................................TNS Series

Other Items .................................................................................................................................. OTH Series
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Table A

Table of Contents

Reference Key Title of Item S&T Page

Subject Series List for the Specifications and Tolerances Committee.................................................. 2

Table 1. Acronyms and Glossary ............................................................................................................ 7

Table 2. Reporting Structure .................................................................................................................. 8

GEN – GENERAL CODE........................................................................................................................ 9

GEN-19.1 D G-T.5. Tolerances on Tests When Transfer Standards are Used., Appendix A, 

Section 3.2. Tolerances for Standards., and Appendix D – Definitions: standards, field., transfer 

standard. and standard, transfer.............................................................................................................. 9

GEN-22.1 V G.A.1. Commercial and Law-Enforcement Equipment......................................... 9

OWM Executive Summary for GEN-22.1 – G.A.1. Commercial and Law-Enforcement Equipment

....................................................................................................................................... 9

SCL – SCALES ........................................................................................................................................ 18

SCL-20.9 W S.1.1.3. Zero Indication, Load Receiving Elements Separate from Weighing 

Elements. And Appendix D – Definitions: no load reference value .................................................... 18

OWM Executive Summary for SCL-20.9 – S.1.1.3. Zero Indication, Load Receiving Elements Separate 

from Weighing Elements. And Appendix D – Definitions: no load reference value........................... 18

SCL-22.2 A UR.1. Selection Requirements, UR.1.X. Cannabis.................................................. 23

LMD – LIQUID MEASURING DEVICES .......................................................................................... 31

LMD-21.1 V Table S.2.2. Categories of Device and Method of Sealing ...................................... 31

OWM Executive Summary for LMD-21.1 – Table S.2.2. Categories of Device and Method of 

Sealing ..................................................................................................................................... 32

LMD-22.1 VTable T.2. Accuracy Classes and Tolerances for Liquid Measuring Devices Covered 

in NIST Handbook 44, Section 3.30 .................................................................................................... 39

OWM Executive Summary for LMD-22.1 – Table T.2. Accuracy Classes and Tolerances for Liquid 

Measuring Devices Covered in NIST Handbook 44, Section 3.30 ...................................................... 39

VTM – VEHICLE TANK METERS..................................................................................................... 44

VTM-18.1 V S.3.1 Diversion of Measured Liquid and S.3.1.1. Means for Clearing the 

Discharge Hose and UR.2.6. Clearing the Discharge on a multiple-product, single discharge hose... 44

OWM Executive Summary for VTM-18.1– S.3.1 Diversion of Measured Liquid and S.3.1.1. Means 

for Clearing the Discharge Hose and UR.2.6. Clearing the Discharge on a multiple-product, single 

discharge hose. ..................................................................................................................................... 44

VTM-20.2 A Table T.2. Tolerances for Vehicle Mounted Milk Meters. ...................................... 55

OWM Executive Summary for VTM-20.2 – Table T.2. Tolerances for Vehicle Mounted Milk 

Meters. ..................................................................................................................................... 55

LIQUIFIED PETROLEUM GAS AND ANHYDROUS lIQUID-MEASURING dEVICES ........... 68

LPG-15.1 D N.3. Test Drafts........................................................................................................ 68

OWM Executive Summary for LPG-15.1 – N.3. Test Drafts. ............................................................. 69

LPG-22.2 W S.2.6. Zero-Set-Back Interlock, for Stationary Customer-Operated Retail MotorFuel Devices, Electronic....................................................................................................................... 80

OWM Executive Summary for LPG-22.2 – S.2.6. Zero-Set-Back Interlock, for Stationary 

Customer-Operated Retail Motor-Fuel Devices, Electronic. ............................................................... 81
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LPG-22.3 D S.2.5. Zero-Set-Back Interlock, Stationary and Vehicle Mounted Meters, 

Electronic., S.2.6. Zero-Set-Back Interlock, Vehicle Mounted Meters, Electronic., and S.2.67. 

Zero-Set-Back Interlock for Stationary Self-Operated Retail Motor-Fuel Devices. ............................ 85

MFM – MASS FLOW METERS........................................................................................................... 93

MFM-15.1 D N.3. Test Drafts........................................................................................................ 93

OWM Executive Summary for MFM-15.1 – N.3. Test Drafts. ........................................................... 94

MFM-22.1 V Table T.2. Accuracy Classes and Tolerances for Mass Flow Meters. ................... 105

OWM Executive Summary for MFM-22.1 Table T.2. Accuracy Classes and Tolerances for Mass 

Flow Meters. ................................................................................................................................... 106

EVF – Electric Vehicle Fueling Systems........................................................................................... 109

EVF-21.1 D A.1. General ........................................................................................................... 109

OWM Executive Summary for EVF-21.1 – A.1. General ................................................................. 109

EVF-20.1 V S.1.3.2. EVSE Value of the Smallest Unit............................................................. 114

OWM Executive Summary for EVF-20.1 – S.1.3.2. EVSE Value of the Smallest Unit. .................. 114

EVF-21.5 D T.2. Load Test Tolerances...................................................................................... 122

OWM Executive Summary for T.2. Load Test Tolerances................................................................ 122

TXI – TAXIMETERS ........................................................................................................................... 128

TXI-22.1 V Table S.5. Categories of Device and Methods of Sealing...................................... 128

OWM Executive Summary for TXI-22.1 – Table S.5. Categories of Device and Methods of Sealing

................................................................................................................................... 128

GMA – GRAIN MOISTURE METERS 5.56 (A)............................................................................... 131

GMA-19.1 D Table T.2.1. Acceptance and Maintenance Tolerances Air Oven Method for All 

Grains and Oil Seeds. ......................................................................................................................... 131

OWM Executive Summary for GMA-19.1– Table T.2.1. Acceptance and Maintenance Tolerances 

Air Oven Method for All Grains and Oil Seeds. ................................................................................ 131

Item GMA-19.1 D Table T.2.1. Acceptance and Maintenance Tolerances Air Oven Method for All 

Grains and Oil Seeds. ......................................................................................................................... 132

MDM – MULTIPLE DIMENSION MEASURING DEVICES ........................................................ 135

MDM-22.1 D S.1.7. Minimum Measurement............................................................................... 135

OWM Executive Summary for MDM-22.1 – S.1.7. Minimum Measurement............ ................... 137 

OTH – OTHER ITEMS........................................................................................................................ 141

OTH-16.1 D Electric Watthour Meters Code under Development ............................................. 141

OWM Executive Summary for OTH-16.1 Electric Watthour Meters Code Under Development..... 141

OTH-22.1 D Appendix A: Fundamental Considerations, 3. Testing Apparatus......................... 147

OTH-22.2 V Appendix D – Definitions: face ............................................................................. 148

OWM Executive Summary for Appendix D – Definitions: face ....................................................... 148

OTH-22.2 Appendix D – Definitions: face ....................................................................................... 148

ITEM BLOCK 1 (B1)TERMINOLOGY FOR TESTING STANDARDS....................................... 151

OWM Executive Summary for Item Block 1 (B1) Terminology for Testing Standards ................... 152

B1: SCL-18.1 W N.2. Verification (Testing) Standards................................................................... 153

B1: ABW-18.1W N.2. Verification (Testing) Standards................................................................... 153

B1: AWS-18.1 W N.1.3. Verification (Testing) Standards, N.3.1. Official Tests, UR.4. Testing 

Standards ................................................................................................................................... 153

B1: CLM-18.1W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards......... 154
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B1: CDL-18.1 W N.3.2. Transfer Standard Test, T.3. On Tests Using Transfer Standards.............. 154

B1: HGM-18.1W N.4.1. Master Meter (Transfer) Standard Test, T.4. Tolerance Application on 

Test Using Transfer Standard Test Method........................................................................................ 154

B1: GMA-18.1W 5.56(a): N.1.1. Air Oven Reference Method Transfer Standards, N.1.3. Meter to 

Like-Type Meter Method Transfer Standards and 5.56(b): N.1.1. Transfer Standards, T. 

Tolerances1

 ................................................................................................................................... 155

B1: LVS-18.1 W N.2. Testing Standards.......................................................................................... 155

B1: OTH-18.1 WAppendix A: Fundamental Considerations, 3.2. Tolerances for Standards, 3.3. 

Accuracy of Standards........................................................................................................................ 156

B1: OTH-18.2 W Appendix D – Definitions: fifth-wheel, official grain samples, transfer standard 

and Standard, Field............................................................................................................................. 156

ITEM BLOCK 2 (B2) DEFINE TRUE VALUE FOR USE IN ERROR CALCULATIONS ...... 163

OWM Executive Summary for Item Block 2 (B2) – Define True Value for Use in Error Calculations

................................................................................................................................... 164

B2: SCL-20.3 A S.5.4. Relationship of Minimum Load Cell Verification Interval to the Scale 

Division ................................................................................................................................... 165

B2: SCL-20.4 A Table 3. Parameters of Accuracy Classes. ............................................................. 166

B2: SCL-20.5 A Table S.6.3.a. Marking Requirements, Note 3....................................................... 167

B2: SCL-20.6 A T.N.1.2. Accuracy Classes and T.N.1.3. Scale Division........................................ 167

B2: SCL-20.8 A Table 8. Recommended Minimum Load ............................................................... 168

ITEM BLOCK 3 (B3) TOLERANCES FOR DISTANCE TESTING IN TAXIMETERS AND 

TRANSPORTATION NETWORK SYSTEMS ................................................................................. 191

OWM Executive Summary for Item Block 3 (B3) – Tolerances for Distance Testing in Taximeters 

and Transportation Network Systems ................................................................................................ 191

Item B3: TXI-20.1 D T. Tolerances................................................................................................... 192

B3: TXI-20.1 D T. Tolerances.......................................................................................................... 192

B3: TNS-20.1 D T. Tolerances.......................................................................................................... 193

ITEM BLOCK 4 (B4) ELECTRONICALLY CAPTURED TICKETS OR RECEIPTS............. 197

OWM Executive Summary for Item Block 4 (B4) – Electronically Captured Tickets or 

Receipts ................................................................................................................................... 198

B4: GEN-21.2 D G-S.5.6. Recorded Representations. ..................................................................... 199

B4: LMD-21.2D S.1.6.5. Money Value Computations., UR.3. Use of a Device. ............................. 199

B4: VTM-21.1D S.1.1. Primary Elements., UR.2. User Requirements............................................. 202

B4: LPG-21.1 D S.1.1. Primary Elements., UR.2. User Requirements............................................. 202

B4: CLM-21.1 D S.1.4.1. Printed TicketRecorded Representation., UR.2.6.3. Printed 

TicketRecorded Representation.......................................................................................................... 205

B4: MLK-21.1D S.1.4.2. Printed Ticket Recorded Representation., UR.2.6.3. Printed 

TicketRecorded Representation.......................................................................................................... 205

B4: MFM-21.2D S.6. PrinterRecorded Representations., UR.2.6. Ticket Printer, Customer Ticket, 

Recorded Representation., UR.3.4. Printed Ticket. Recorded Representation. ................................. 205

B4: CDL-21.1 D S.1.4.1. Printed TicketRecorded Representations., UR.2.4.2. Tickets or Invoices. 

Recorded Representation.................................................................................................................... 206

B4: HGM-21.1D S.2.6. Recorded Representations, Point of Sale Systems., S.6. Printer. Recording 

Element., UR.3.2. Vehicle-mounted Measuring Systems Ticket Printer Recording Element., 

UR.3.3. Printed Ticket. Recorded Representation.............................................................................. 207
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B4: OTH-21.2 D Appendix D - Definitions.: recorded representations, recording element.............. 208

ITEM BLOCK 5 (B5) DEFINE “FIELD REFERENCE STANDARD”.......................................... 214

OWM Executive Summary for Item Block 5 (B5) Define “Field Reference Standard”.................... 214

B5: CLM-18.2 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards........ 215

B5: CDL-18.2 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards........ 215

B5: HGM-18.2W N.4.1. Master Meter (Transfer) Standard Test and T.4. Tolerance Application on 

Test Using Transfer Standard Test Method........................................................................................ 216

B5: OTH-18.3 W Appendix D – Definitions: field reference standard meter and transfer standard . 216

ITEM BLOCK 6 (B6) COMMERCIAL AND LAW ENFORCEMENT, AXLE AND AXLE 

GROUP WEIGHTS .............................................................................................................................. 218

OWM Executive Summary for Item Block 6 (B6) Commercial and Law Enforcement, Axle and 

Axle Group Weights........................................................................................................................... 219

B6: SCL-22.1 Recorded Representation of Axle or Axle Group Weights........................................ 220

B6: SCL-22.3 D UR.3.3. Single-Draft Vehicle Weighing., and UR.3.4. Axle and Axle Group 

Weight Values. ................................................................................................................................... 221

ITEM BLOCK 7 (B7) TOLERANCES ON TESTS USING TRANSFER STANDARDS .......... 232

OWM Executive Summary for Item Block 7 (B7) – Tolerances on Tests Using Transfer Standards

................................................................................................................................... 233

B7: CLM-22.1 D T.3. On Tests Using Type 2 Transfer Standards................................................... 234

B7: CDL-22.1 D T.3. On Tests Using Type 2 Transfer Standards.................................................. 234

B7: HGM-22.1 D T.4. Tolerance Application on Tests Using Type 2 Transfer Standard Test 

Method. ................................................................................................................................... 234

ITEM BLOCK 8 (B8) G-T.5. TOLERANCES ON TESTS WHEN TRANSFER STANDARDS ARE 

USED., APPENDIX A, SECTION 3.2. TOLERANCES FOR STANDARDS., AND APPENDIX D – 

DEFINITIONS: STANDADS, FIELD., TRANSFER STANDARD. AND STANDARD, 

TRANSFER. APPENDIX A: FUNDAMENTAL CONSIDERATIONS, 3. TESTING APPARATUS

 ............................................................................................................................................................ 236

B8: GEN-19.1 D G-T.5. Tolerances on Tests When Transfer Standards are Used., Appendix A, 

Section 3.2. Tolerances for Standards., and Appendix D – Definitions: standards, field., transfer 

standard. and standard, transfer. ......................................................................................................... 236

B8: OTH-22.1 DAppendix A: Fundamental Considerations, 3. Testing Apparatus......................... 237

OWM Executive Summary for Item Block 8 (B8) G-T.5. Tolerances on Tests When Transfer 

Standards Are Used, Appendix A, Section 3.2. Tolerances for Standards., and Appendix D – 

Definitions: Standards, Field., and Standard, Transfer. Appendix A: Fundamental Considerations, 

3. Testing Apparatus........................................................................................................................... 239
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Table 1. Acronyms and Glossary

ABWS Automatic Bulk Weighing System

AAR Association of American Railroads

API American Petroleum Institute

CNG Compressed Natural Gas

CWMA Central Weights and Measures Association

EPO Examination Procedure Outline

FHWA Federal Highway Administration

GMM Grain Moisture Meter

GPS Global Positioning System

HB Handbook

LMD Liquid Measuring Devices

LNG Liquefied Natural Gas

LPG Liquefied Petroleum Gas

MMA Meter Manufacturers Association

MDMD Multiple Dimension Measuring Device

NCWM National Conference on Weights and Measures

NEWMA Northeastern Weights and Measures Association

NIST National Institute of Standards and Technology

NTEP National Type Evaluation Program

OIML International Organization of Legal Metrology

OWM Office of Weights and Measures

RMFD Retail Motor Fuel Dispenser

S&T Specifications and Tolerances

SD Secure Digital

SI International System of Units

SMA Scale Manufactures Association

SWMA Southern Weights and Measures Association

TC Technical Committee

USNWG U.S. National Work Group

VTM Vehicle Tank Meter

WIM Weigh-in-Motion
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WWMA Western Weights and Measures Association

Table 2. Reporting Structure

Source: Name and affiliation of submitter. 

Purpose and Justification: The submitter’s concise statement as to the intent or purpose of this 

proposal. The justification describes the national importance, background on the issue, and may contain 

references to supporting data or documents. The justification may be summarized by OWM.

OWM Executive Summary: High level points that summarize the Technical Aspects of the item and 

recommendations pertaining to the Item under Consideration.

Table 3. Summary of Recommendations

Item under Consideration – The latest language that the Committee has moved forward as the Item 

membership is considering

NIST OWM Detailed Technical Analysis – A detailed analysis with background information and 

recommendations from the Office of Weights and Measures (OWM)

Summary of Discussions and Actions – An OWM summary of details and discussion on this 

Item. This includes discussion and decisions of the Standing Committee. This may also include 

information from sectors, trade associations, task groups, and subcommittees.

Regional Association Reporting - Taken directly from the Regional Association Meeting finalized 

report.

• Each region will be identified separately.

• The meetings within each region will be in chronological order.

• This information is taken directly from the Regional Association final report.

• The Technical Advisor may reach out to the regional Chair for clarification.
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Details of All Items

(In order by Reference Key)

GEN – GENERAL CODE

GEN-19.1 D G-T.5. Tolerances on Tests When Transfer Standards are Used., Appendix A, 

Section 3.2. Tolerances for Standards., and Appendix D – Definitions: standards, 

field., transfer standard. and standard, transfer. 

This item was modified and combined with Item OTH-22.1 and is now Block 8.

GEN-22.1 V G.A.1. Commercial and Law-Enforcement Equipment.

Source: NIST Office of Weights and Measures

Purpose and Justification:

This proposed change is intended to add clarification regarding the implications of using weighing and 

measuring devices for transactions that may be considered by some as commercial while there is no clear 

guidance provided.

OWM Executive Summary for GEN-22.1 – G.A.1. Commercial and Law-Enforcement 

Equipment

OWM Recommendation: OWM believes GEN-22.1 is fully developed and recommends its’ adoption 

along with the two companion L&R items. 

• This item is intended to eliminate all ambiguity concerning the issue of whether or not NIST 

Handbook 44 is intended to apply to weighing and measuring equipment used solely for the purpose 

of charging a fee for the service of providing a weight or measure.

• This item is somewhat related to the two remaining S&T scale items in Block 6, from which this item 

was removed by the Committee during the 2022 NCWM Interim Meeting and made a stand-a-lone 

voting item. The remaining two scale items are currently developing items.

• There are also two companion items on L&R’s agenda related to S&T GEN-22.1, both of which are 

also voting items. The L&R items are B2: WAM-22.1 and NTP-22.1. These two L&R items were 

developed by OWM to harmonize the language associated with the terms “commercial” and “law 

enforcement” in NIST Handbook 44 and NIST Handbook 130.

Table 3. Summary of Recommendations

GEN-22.1 – G.A.1. Commercial and Law Enforcement Equipment

V D W A I Notes* Comments

Submitter 
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Table 3. Summary of Recommendations

GEN-22.1 – G.A.1. Commercial and Law Enforcement Equipment

V D W A I Notes* Comments

OWM 

WWMA  1

SWMA 

NEWMA 

CWMA  1

NCWM 

Letters of 

Support

Letters of 

Opposition Comments

Industry

Manufacturers SMA supports this item

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered 

Item under Consideration:

Amend Handbook 44, General Code as follows: 

G-A.1. Commercial and Law-Enforcement Equipment. – These specifications, tolerances, and other 

technical requirements apply as follows.

(1) To commercial weighing and measuring equipment; that is:

(a) To weights and measures and weighing and measuring devices commercially used or 

employed in:

1. establishing the size, quantity, extent, area, composition (limited to meat and poultry), 

constituent values (limited to grain), or measurement of quantities, things, produce, or 

articles for distribution or consumption, purchased, offered, or submitted for sale, hire,

or award;

2. assessing a fee for the use of the equipment to determine a weight or measure;

3. determining the basis of an award using count, weight, or measure; or
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4. computing any basic charge or payment for services rendered on the basis of weight or 

measure.

(Amended 2008 and 20XX) 

(b) To any accessory attached to or used in connection with a commercial weighing or 

measuring device when such accessory is so designed that its operation affects the accuracy 

of the device.

(2) To weighing and measuring equipment in official use for the enforcement of law or for the 

collection of statistical information by government agencies.

(These requirements should be used as a guide by the weights and measures official when, upon request, 

courtesy examinations of noncommercial equipment are made.)

NIST OWM Detailed Technical Analysis:

This item was originally a part of the Block 6 S&T items but was removed by the Committee and made a 

stand-alone voting item during the 2022 NCWM Interim Meeting at the recommendation of OWM and 

others. As a result, only two “scale” items remain in Block 6 of the Committee’s 2022 Interim Meeting 

Report (NCWM Publication 16). Those items are SCL-22.1 and SCL-22.3 and both remain in a developing 

status. Refer to Block 6 of this report to view OWM’s analysis of these two items.

OWM developed the proposal in GEN-22.1 and the two proposals in SCL-22.1 and SCL-22.3 to:

1. remove all ambiguity surrounding the issue of whether or not NIST Handbook 44 is intended to 

apply to weighing and measuring equipment used solely for the purpose of providing a weight or 

measure for a fee; and

2. address perceived gaps in HB 44 Scales Code requirements pertaining to the design and use of 

multi-independent platform vehicle scales used to charge a fee for the service of providing axleand axle-group weights, as well as total vehicle weight to those needing them (typically commercial 

haulers). 

These (3) proposals were developed as the result of an OWM inquiry from a state questioning the 

permissible use of a multi-independent platform vehicle scale system (each platform having its own A/D 

conversion circuitry and weight indicator) that printed total vehicle weight from summing the axle- and 

axle-group loads of vehicles weighed when not all parts of those vehicles were able to fit onto a live portion 

of the scale and be weighed simultaneously. That is, the scale was being used on occasion to “split weigh” 

in two different drafts the different axle and axle groups of “over-sized” coupled vehicle combinations 

because not all axle and axle groups would fit onto a live portion of the scale at the same time, which thus 

necessitated weighing those particular vehicles in multiple drafts. Even though the printed ticket provided 

clear indication that the total vehicle weight value recorded was “non certifiable,” it is questionable whether 

or not the scale system would be permitted to record this weight since HB 44 Scales Code paragraph UR.3.3. 

Single-Draft Vehicle Weighing requires a vehicle or coupled-vehicle combination to be weighed on a 

vehicle scale only as a single draft.

The two scale items in Block 6 are intended to address the design and use of multi-independent platform 

vehicle scale systems, including the weight information that gets displayed and recorded by these systems 

when in use. OWM developed the GEN-22.1 proposal when it became evident from discussions with 
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various states that not all jurisdictions interpreted paragraph G-A.1. to mean that HB 44 was intended to 

apply to weighing and measuring devices and systems used solely to charge a fee for the service of 

providing a weight or measure and for no other purpose. Consequently, Gen-22.1 is intended to make clear 

the application of HB 44 to weighing and measuring equipment used to charge a fee for the service of 

providing a weight or measure but could also be used for commercial uses. 

Based on the feedback received during the fall 2021 regional weights and measures association meetings 

and the 2022 NCWM Interim Meeting, OWM concluded that most everyone seemingly agrees that NIST 

Handbook 44 is intended to apply to weighing equipment used in assessing a fee for the service of providing 

a weight. It is only reasonable to expect that when a device is used for the purpose of charging a fee for a 

weight or measure that that weight or measure be accurate, (i.e., to within the applicable tolerances specified 

in HB 44), and that the device used for this service comply with all applicable HB 44 requirements. 

Clarifying this point was OWM’s objective in proposing a change to paragraph G.A.1. Commercial and 

Law-Enforcement Equipment. 

Summary of Discussions and Actions:

The S&T Committee agreed at the request of OWM and others during the 2022 NCWM Interim Meeting 

to restructure the information in the GEN-22.1 proposal from that which was initially drafted and appearing 

in the Committee’s 2022 NCWM Interim Meeting Agenda. This restructuring was done to harmonize the 

GEN-22.1 item with two “companion items” on the Laws and Regulations Committee’s 2022 agenda that 

define the term “commercial equipment.” This S&T item, following its restructuring, then received 

widespread support from those commenting on it during open hearings. 

The Specifications and Tolerances Committee and Laws and Regulations Committee agreed to meet 

virtually following the 2022 NCWM Interim Meeting to make any final changes necessary to harmonize 

the different proposals. No changes were recommended to this item during that meeting and the Committee 

agreed to recommend for vote the proposal as shown in the Item under Consideration of this report at the 

2022 NCWM Annual Meeting. 

Regional Association Reporting:

Western Weights and Measures Association

At the 2021 WWMA Open Hearings, the following comments on all three items originally in Block 6 to 

include GEN-22.1, SCL-22.1, and SCL-22.3 were heard:

Mr. Kurt Floren (Los Angeles County, California): He wants to offer that the last part of subsection A and 

breaking into bullet points. He wants to break out equipment that is commercial, then the other types. It’s 

titled commercial and law enforcement then “other commercial” and it becomes confusing. Is it all 

commercial and subsect to our jurisdiction. Rephrase GA-1 : apply “to commercial equipment as follows”: 

... explains that everything under is commercial (strike “commercial” from A and B). Between apply and 

as in the first line, insert commercial equipment. Mr. Floren stated that he will submit a written statement 

to the Committee as presented during open hearings. 

Mr. Ivan Hankins (Iowa) wants clarification as to what is being changed to make it better. It looks like it’s 

already there, and he wants more definition on why this is changing.
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Ms. Cadence Matijevich (Nevada) agrees with Kurt, but cautions that we consider how the heading reads 

if we add commercial to the opening statement then there might be some interpretation that what is or is

not commercial law enforcement equipment. (Is there a fine assessed?) Does not want to narrow the 

subsection of law enforcement devices only to commercial purposes.

Mr. Kurt Floren (Los Angeles County, California): fix to Ms. Cadence Matijevich: restructure under GA1: insert subsection under 1: commercial as follows, then insert A,B,C, then 2 for law enforcement.

Ms. Cadence Matijevich (Nevada) stated that Mr. Floren is much better at this, and his fix is good. 

Mr. Lou Straub (Fairbanks Scales): agrees with Mr. Hankins, that the original language is satisfactory. 

Language needs to say that its NTEP approved and meets handbook requirements. 

Mr. Eric Golden (Cardinal Scale): Does a commercial transaction include just getting a weight: he says 

yes. Change the wording that that transaction is commercial. No suggestions at this time. Kurt missed a 

typo: in B2: “Basis”. 

Mrs. Tina Butcher (NIST OWM): their office submitted this. Wanted to clarify commercial transactions. 

Agrees with previous testimony. They have submitted other proposals to amend method of sale reg. and 

uniform law. They have determined that HB 44 and 2 sections in HB 130 are slightly different. Uniform 

Reg. for service persons also needs to be aligned. Wants this to remain developing so that they can continue 

to align the language and make it more uniform.

Mr. Russell Vires (Scale Manufactures Association): This is a new item, the SMA has not vetted this yet. 

They will do so at November meeting. This should remain developing so that there’s no unintended 

consequences.

Mrs. Tina Butcher (NIST OWM): In the agenda, this is blocked with two other “companions”. She feels 

that the block should continue, however, if others think that other items in the block are ready (SCL-22.1 

and SCL-22.3) those items can move forward.

Mr. Don Onwiler (NCWM): SCL-22.3 is the name of the next item. 

Mr. Russell Vires (Scale Manufactures Association): he is looking at it as a block and is commenting as 

an entire block. Wants all 3 to remain developing so that they can research.

Mr. Lou Straub (Fairbank Scales): SCL-22.1: concern about the second sentence: talking about the entire 

truck on the scale = not legal for trade: this is ok. Second part about axle identifications (axle groups) this 

gets difficult to identify group notifications. Wants the ticket that has already been marked as not legal for 

trade to not have to identify all axels. Wants this re-worded. They will put down axle weight and gross 

weight. Preprinted labels don’t allow enough space.

Mr. Eric Golden (Cardinal Scales): agrees with Mrs. Butcher to split the items. “Blow the block apart.” 

The second two items introduce additional items and topics. Wants to pull the second two items out.

The WWMA S&T Committee recommends that this be assigned a Developmental status. The Committee 

recommends following the submitter’s request to remove GEN-22.1 from the Block. Based on testimony 

heard the Committee agreed to submit the following language for item GEN-22.1. The Committee notes 

that SCL-22.1 (UR.3.3.) item was reassigned as SCL-22.3. 
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G-A.1. Commercial and Law-Enforcement Equipment. – These specifications, tolerances, and 

other technical requirements apply as follows:

(1) To commercial weighing and measuring equipment

(a) To commercial weighing and measuring equipment; that is, tTo weights and measures and 

weighing and measuring devices commercially used or employed in establishing the size, 

quantity, extent, area, composition (limited to meat and poultry), constituent values (limited to 

grain), or measurement of quantities, things, produce, or articles for distribution or 

consumption, purchased, offered, or submitted for sale., hire, or award, or in computing any 

basic charge or payment for services rendered on the basis of weight or measure.

(Amended 2008 and 20XX) 

(b) To other commercial weighing and measuring equipment:

i. when there is a fee assessed for the use of the equipment to determine a weight or 

measure;

ii. used to determine the bases of an award using count, weight, or measure; or

iii. used in computing any basic charge or payment for services rendered on the basis of 

weight or measure

(Added 20XX)

(bc) To any accessory attached to or used in connection with a commercial weighing or measuring 

device when such accessory is so designed that its operation affects the accuracy of the device. 

(cd)(2) To weighing and measuring equipment in official use for the enforcement of law or for the 

collection of statistical information by government agencies.

(These requirements should be used as a guide by the weights and measures official when, upon request, 

courtesy examinations of noncommercial equipment are made.)

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Russ Vires (Mettler Toledo), stated that this item needs 

work on the wording and further review by stakeholders. Its current language could have unintended 

consequences, and recommended it continue with a Developing Status. 

This Committee would like clarification on the purpose and use of axle weight scale values allowed by this 

proposal beyond law enforcement use. 

This Committee recommends that this item move forward with a Developing status. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

GEN-22.1 

Mr. Rick Harshman (NIST OWM) commented that the language is in-need of some changes and NIST will 

be providing changes for the NCWM. Mr. Eric Golden (Cardinal Scale) supports the intent of this item, 
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but it may need some wordsmithing. Mr. Lou Straub (SMA), Ms. Cheryl Ayer (New Hampshire), and Mr. 

John McGuire (New Jersey) all support this as a developing item.

SCL 22.1

Mr. Eric Golden (Cardinal Scale) supports this item moving forward as developing. Mr. Lou Straub 

(Fairbanks Scale) agrees with language in general. But questions the benefit of including all the language 

on a scale ticket and the large amount of information would be difficult to fit on the ticket. Mr. Eric Golden 

(Cardinal Scale) and Ms. Cheryl Ayer (New Hampshire) agree with comments from Mr. Straub. Mr. John 

McGuire (New Jersey) recommends keeping this item in Developing status.

SCL 22.3

Mr. Eric Golden (Cardinal Scale) suggested to strike “non-commercial” and additional wordsmithing to 

align with paragraph UR3.4. Mr. John McGuire (New Jersey) supports keeping this item in developing 

status.

The NEWMA Specifications and Tolerances Committee recommends that this item be given a Developing 

Status. 

During NEWMA’s 2022 Annual Meeting Open Hearings, the following comments were heard:

Mrs. Tina Butcher (NIST OWM) commented that the intent is to remove ambiguity as there is an 

expectation for customers to receive an accurate weight when not used as a typical commercial device. She 

believes the item is ready as presented and language aligns with L&R items with terms “commercial” and 

“law enforcement”. Mr. Russ Vires (SMA) commented that SMA supports the item as voting as it provides 

clarity of what constitutes a commercial transaction. Mr. John McGuire (NJ) commented as the NCWM 

L&R Chair and indicated that both NCWM L&R and S&T committees met in February 2022 to align this 

item with the L&R items. 

Upon hearing these comments, the Committee considered the item to be fully developed and recommended 

that the item retains Voting status. 

Central Weights and Measures Association

During the 2021 CWMA Interim Meeting the committee heard comments from the floor on all three items 

originally in Block 6 to include GEN-22.1, SCL-22.1, and SCL-22.3 as follows:

Mr. Loren Minnich (Kansas) suggested change he sent to the committee (in green).

B6: GEN-22.1 G-A.1. Commercial and Law-Enforcement Equipment. – These specifications, 

tolerances, and other technical requirements apply as follows:

(a) To commercial weighing and measuring equipment; that is, to weights and measures and 

weighing and measuring devices commercially used or employed in establishing the size, 

quantity, extent, area, composition (limited to meat and poultry), constituent values (limited to 

grain), or measurement of quantities, things, produce, or articles for distribution or 

consumption, purchased, offered, or submitted for sale., hire, or award, or in computing any 

basic charge or payment for services rendered on the basis of weight or measure.

(Amended 2008 and 20XX) 

(c) To other commercial weighing and measuring equipment:
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i. when there is a fee assessed for the use of the equipment to determine a weight or 

measure;

ii. used to determine the bases of an award using count, weight, or measure when using 

weight, measure, or count as the basis to determine an award; or

iii. used in computing any basic charge or payment for services rendered on the basis of 

weight or measure

(Added 20XX)

Mr. Loren Minnich (Kansas) also asked NIST for clarification on G-A.1. because different states already 

interrupt rule different ways. Ms. Diane Lee (NIST) agreed with Mr. Minnich and suggested it be 

Developing. Mr. Eric Golden (Cardinal Scales) agreed with the spirit of the proposal; it is indeed a 

“commercial transaction” to charge a person a fee solely for the purpose of obtaining a weight of a vehicle 

– it is not required to have to undergo a sales transaction of weighed product in order for it to be considered 

a commercial transaction. Mr. Golden also recommended striking out the following (in red) stating the 

reasoning behind this is by leaving the “non-commercial” language in the proposal, it defeats the purpose 

of the proposal, which is to officially clarify what a non-commercial transaction is.

B6: SCL-22.1 S.1.14. Recorded Representation of Axle or Axle Group Weights

S.1.14. Recorded Representation of Axle or Axle Group Weights. – The recorded 

representation of weights from individual axle or axle group weights shall clearly be identified 

as “not legal for trade” or “non-commercial” weight values unless the entire vehicle is 

positioned on live elements of a multiple-platform vehicle scale and where all axles/axle 

groups are weighed simultaneously. All recorded weights of axles/axle groups shall be 

identified as representing only a portion of the vehicle’s total gross weight (e.g., by axle 

groupings such as: “axle group 1,” “axle group 2,” “axle group 3,” or by individual axle 

description such as: “steering axle,” “drive axles,” “trailer axles”).

Any total gross weight of the vehicle included in the recorded representations determined by 

summing axle weights shall be clearly identified as “not-legal-for trade” or “noncommercial” unless those axle weights were recorded when all parts of the vehicle rested 

simultaneously on live portions of the scale, or the individual components were uncoupled, 

positioned completely on the live elements, and weighed separately on the scale.

Mrs. Tina Butcher (NIST OWM) agreed G-A.1. needed more work and had no objection to Mr. Golden’s 

suggestion of splitting SCL-22.1 and SCL-22.3. Mr. Lou Straub (Fairbanks) said current G-A.1. is already 

correct. He also agreed with Mr. Golden from Cardinal Scales on SCL 22.1. Mr. Doug Musick (Kansas) 

agreed with Mr. Straub. He said that the item is not practical for all vehicles out there. Keep as Developing. 

Mr. Ivan Hankins (Iowa) felt that G-A.1. is already correct. Mr. Charles Stutesman (Kansas) stated original 

language is good as written.

CWMA S&T Committee recommends that GEN 22.1 be withdrawn and SCL-22.1 and SCL 22.3 remain 

Developing.

During the 2022 CWMA’s Annual Meeting Open Hearings, the following comments were heard:

Mr. Jan Konijnenburg (NIST OWM) stated fully developed and ready for a vote. Mr. Russ Vires (SMA) 

supported the item. Mr. Konrad Crockford (North Dakota) supported the item. Mr. Charles Stutesman 
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(Kansas) believed final determination of a device should be decided by the local jurisdiction and item should 

not move forward. Mr. Doug Musick (Kansas) said the word commercial should be stricken from Line 13 

on page 149 as well as Line 6 on page 150. 

The CWMA S&T Committee believes this item is fully developed and should remain a voting item with 

the following changes: Page 149 Line 13, (1) To commercial weighing and measuring equipment; that 

is:

Scale Manufacturers Association (SMA-Fall 2021 Meeting)

The SMA offered the following technical positions from its November 2021 Meeting on the three items 

originally in Block 6 to include GEN-22.1, SCL-22.1, and SCL-22.3 as follows: 

The SMA recommends that Block 6 be broken apart into three (3) individual items because each of these 

items deals with a separate topic that needs to be discussed individually.

B6: GEN-22.1 G.A.1. Commercial and Law-Enforcement Equipment 

The SMA supports this item. The proposed item provides clarity to define what constitutes a “commercial 

transaction.” 

B6: SCL-22.1 S.1.14. Recorded Representation of Axle Group Weights

The SMA supports this item with the following changes (shown as shaded and struck-through text):

S.1.14. Recorded Representation of Axle or Axle Group Weights. – The recorded representation of 

weights from individual axle or axle group weights shall clearly be identified as “not legal for trade” 

or “non-commercial” weight values unless the entire vehicle is positioned on live elements of a 

multiple-platform vehicle scale and where all axles/axle groups are weighed simultaneously. All 

recorded weights of axles/axle groups shall be identified as representing only a portion of the vehicle’s 

total gross weight (e.g., by axle groupings such as: “axle group 1,” “axle group 2,” “axle group 3,” or 

by individual axle description such as: “steering axle,” “drive axles,” “trailer axles”). 

Any total gross weight of the vehicle included in the recorded representations determined by 

summing axle weights shall be clearly identified as “not-legal-for trade” or “non-commercial” unless 

those axle weights were recorded when all parts of the vehicle rested simultaneously on live portions 

of the scale, or the individual components were uncoupled, positioned completely on the live elements, 

and weighed separately on the scale.

Rationale: The item attempts to define what constitutes a “commercial transaction”, but the words “noncommercial” reduces its clarity. Secondly, it is not necessary to label each weight value of axle/axle group 

weights as “not legal for trade”; putting the words “not legal for trade” on the recorded representation once 

is adequate.

B6: SCL-22.3 UR.3.3. Single-Draft Vehicle Weighing, and UR.3.4. Axle and Axle Group Weight 

Values

Position: The SMA supports this item.

SMA-Spring 2022 Meeting 
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Position: The SMA supports this item (i.e., GEN-22.1.). 

Rationale: The proposed item provides clarity to define what constitutes a “commercial transaction.”

SCL – SCALES

SCL-20.9 W S.1.1.3. Zero Indication, Load Receiving Elements Separate from Weighing 

Elements. And Appendix D – Definitions: no load reference value

Note: This item was carried over from the 2020 Interim Meeting however, it was not a Voting item and 

therefore not discussed during the continuation of the 2020 Annual Meeting. Instead, the item was placed 

on the 2021 Interim Meeting’s agenda and was discussed during that meeting.

The original 2021 Interim Meeting Report did not include the updated Item Under Discussion. It was

corrected for Publication 16 on May 27, 2021. 

Source: Kansas Department of Agriculture

Purpose and Justification:

This item is intended to be applied to weighing devices utilizing a hopper that, once programmed, weigh in 

multiple drafts to complete the weighing cycle (automatic operation) and that in the course of the normal 

weighing cycle may not return to zero because of material remaining in the hopper.

OWM Executive Summary for SCL-20.9 – S.1.1.3. Zero Indication, Load Receiving 

Elements Separate from Weighing Elements. And Appendix D – Definitions: no load 

reference value

OWM Recommendation: No recommendation. This item was withdrawn at the 2022 Interim Meeting.

Table 3. Summary of Recommendations

SCL -20.9 – S.1.1.3 Zero Indication, Load Receiving Elements Separate from Weighing Elements, 

Appendix D – Definitions: no load ref value 

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM
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Table 3. Summary of Recommendations

SCL -20.9 – S.1.1.3 Zero Indication, Load Receiving Elements Separate from Weighing Elements, 

Appendix D – Definitions: no load ref value 

V D W A I Notes* Comments

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Scales Code as follows:

S.1.1.2. No-Load Reference Value. – 

S.1.1.2.1. Single Draft Manually Operated Receiving Hopper.- On a single draft manually 

operated receiving hopper scale installed below grade, used to receive grain, and utilizing a no-load 

reference value, provision shall be made to indicate and record the no-load reference value prior to 

the gross load value.

(Added 1983)

S.1.1.2.2. Digital Indicating Hopper Scales Designed for Automatic Operation- Provisions shall 

be made to indicate and record a no-load reference value on both sides of zero 

(Nonretroactive as of January 1, 20XX)

S.2.1. Zero-Load Adjustment.

S.2.1.7. Digital Indicating Hopper Scales Designed for Automatic Operation. – The weighing 

system shall be equipped with semiautomatic means by which the zero-load may be adjusted 

when the indication is stable within plus or minus 1.0 scale division and the weighing cycle is 

not in operation. 

Automatic zero-tracking and automatic zero-setting mechanisms shall not operate during the 

weighing cycle.

(Nonretroactive as of January 1, 20XX)

S.2.6. Weighing and Recording Sequence for Digital Indicating Hopper Scales Designed for 

Automatic Operation_ 

S.2.6.1. Weighing Sequence. – For weighing systems used to receive (weigh in), the no-load 

reference value shall be determined and recorded only at the beginning of each weighing cycle. 

For systems used to deliver (weigh out), the no-load reference value shall be determined and 

recorded only after the gross load reference value for each weighing cycle has been indicated 

and recorded.

(Nonretroactive as of January 1, 20XX)
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S.2.6.2. Recording Sequence. – Provision shall be made so that all weight values are indicated 

until the completion of the recording of the indicated value.

(Nonretroactive as of January 1, 20XX)

S.3.4. Interlocks and Flow Control-Digital Indicating Hopper Scales Designed for Automatic 

Operation. 

S.3.1. Flow Control. – Provision shall be made to clearly indicate to the operator the status of 

product flow to and from the weigh hopper.

S.3.2. Interlocks. – Each system shall have operating interlocks to provide for the following:

(a) Product cannot be cycled and weighed if the weight recording element is disconnected or 

subjected to a power loss.

(b) The recording element cannot print a weight if either of the flow control mechanism 

leading directly to or from the weigh hopper is operating.

(c) A “low paper” sensor, when provided, is activated.

(d) The system will operate only in the proper sequence in all modes of operation. 

(e) When an overfill alarm is activated, the system shall indicate and record an overfill 

condition.

S.3.5. Overfill Sensor.

(a) The load-receiving element shall be equipped with an overfill sensor which will cause the 

flow control mechanism filling the load-receiving element to become inactive, activate an 

alarm, and inhibit weighing until the overfill condition has been corrected.

(b) If the system is equipped with a lower garner or surge bin, that garner shall also be equipped 

with an overfill sensor which will cause the flow control mechanism emptying the loadreceiving element to remain open, activate an alarm, and inhibit weighing until the overfill 

condition has been corrected.

[Nonretroactive as of January 1, 20XX]

And amend Appendix D – Definitions as follows:

no-load reference value. – A positive or negative weight value indication with no load in the loadreceiving element of a scale. (Used with automatic bulk-weighing systems and certain single-draft, 

manually-operated receiving hopper scales installed below grade and used to receive grain.) [2.20, 

2.22]

NIST OWM Detailed Technical Analysis:

The submitter of this item (State of Kansas) requested its withdrawal during S&T open hearings at the fall 

2021 CWMA meeting. Based on the submitters recommended withdrawal, OWM offers no comments and 

recommendation on this item.
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Summary of Discussions and Actions:

This item has been assigned to the submitter for further development. For more information or to provide 

comment, please contact:

Mr. Doug Musick

Kansas Department of Agriculture

(785) 564-6681, doug.musick@ks.gov

There are many devices currently in use that, when not returned to zero, produce an inaccurate weighment. 

For example, a hopper scale used to weigh aluminum cans. The hoppers of these scales tend to become 

very sticky from residue and cans may stick to the side. When the indicator does not return to zero the 

operator will typically re-zero the scale to begin the next weighment. If the operator does not notice the 

device didn’t return to zero, they may pay for the same cans more than once. If the device is re-zeroed with 

the can still stuck and it is knocked loose later, the customer may be paid for less material than they brought 

to the facility if the operator does not notice the indicator is below zero. If properly operated, a system 

utilizing a load-receiving element separate from a weighing element can be used to determine an accurate 

net weight.

In some cases, the load receiving element of a scale will retain materials (in the case of a hopper scale often 

referred to as the “heel”). This is typically a positive value but if the operator manually re-zero’s the 

indicator and the material is subsequently cleared this can result in a negative value and should be accounted 

for when determining a net weight.

At the NCWM 2020 Interim Meeting, the submitter (Mr. Musick) stated the intent of this item was directed 

towards weighing systems utilizing hoppers and tanks and that his understanding of the NIST OWM 

analysis is that the intent of the proposal may not have been clear and will work towards clarifying the 

purpose of the item. Mr. Musick requested the committee assign a Developing Status. A representative of 

the NIST OWM indicated he had discussed the item with the submitter and is willing to work with him to 

assist in the development of the item. 

A representative of the SMA commented that their group is opposed to the item because the intent is not 

understood. 

During the Committee’s work session, the Committee assigned this item a Developing status.

At the NCWM 2020 Annual Meeting, due to the 2020 COVID-19 pandemic, this meeting was adjourned 

to January 2021, at which time it was held as a virtual meeting. Due to constraint of time, only those items 

designated as 2020 Voting Items were addressed. All other items were addressed in the subsequent 2021 

NCWM Interim Meeting.

At the 2021 NCWM Interim Meeting, the Committee heard testimony in the open hearing session from Mr. 

Loren Minnich (Kansas, submitter) stating that this proposal would replace another proposal from this 

submitter (ABW-16.1) which the submitter is recommending Withdraw. Mr. Minnich recommended an 

Information or Developing status for this item. Mr. Russ Vires (SMA) stated that the SMA takes no position 

on this item. Mr. Kevin Schnepp (California Division of Measurement Standards) supports a Developing 

status for the item.
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During the 2021 Interim Meeting work session, the Committee recommended the submitter continue to 

work with NIST OWM to further develop this item and agreed the item should remain as a Developing 

status.

At the 2022 NCWM Interim Meeting, the Committee heard from Mr. Loren Minnich (Kansas, submitter) 

that he requested the item be withdrawn. Mr. Russ Vires (SMA) stated they oppose the item and feel it is 

an application issue. The Committee agreed to withdraw this item.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard: Mr. Russell Vires 

(SMA): carryover item. SMA opposes item in current form. The potential problem is an application issue 

and not specification issue. Their position is recorded on the NCWM website. 

The WWMA S&T Committee recommends the status remain developmental so that the submitter can 

continue to work on this as they have previously stated. 

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Russ Vires, SMA, stated that he opposes this item 

because he believes it’s an application issue, not a specifications issue, citing that the submitter has 

requested it remain developmental. 

This S&T Committee recommends this item remain a Developing status. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearings, no comments were heard, and the submitter was not 

available.

The S&T Committee recommends that this item remain in Developing Status. 

During the 2022 Annual Meeting open hearings no comments were received because this item was 

withdrawn at the 2022 Interim Meeting.

Central Weights and Measures Association 

During the 2021 Interim Meeting Open Hearing, the Committee heard comments from the floor. Mr. Loren 

Minnich (Kansas) (submitter) suggested withdraw. Mr. Lou Straub (SMA) does not support item, feels it’s 

an application issue not a specifications item. 

CWMA S&T Committee supports the submitter request to withdraw.

During the CWMA 2022 Annual Meeting Open Hearing no comments were received because this item was 

withdrawn at the 2022 Interim Meeting.
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SMA

During the SMA 2021 fall meeting, the SMA opposed this item in its current form. The SMA believed that 

the potential problem the item is attempting to address is an application issue, not a specification issue.

SCL-22.2 A UR.1. Selection Requirements, UR.1.X. Cannabis 

Source: NCWM Cannabis Task Group

Purpose and Justification:

Establish uniform scale suitability requirements among the states for sales of cannabis. 

OWM Executive Summary for SCL-22.2 – UR.1. Selection Requirements, UR.1.X. 

Cannabis

OWM Recommendation: For these reasons, OWM recommends this item be withdrawn. A muchpreferred approach would be to develop a guidance document, taking into account all scale suitability 

factors thereby continuing to provide officials the discretion they currently possess to making final scale

suitability determinations based on the results of their inspection. 

• Suitability requirements should be applied independent of the product being weighed. It raises the 

question, “Why only cannabis and not other products?” 

• There are many significant factors that need to be considered when determining whether or not a 

particular scale is suitable for its intended application. For example, the smallest, largest, and average 

loads to be weighed on the scale; the scale’s minimum division value; the various unit prices of 

commodities weighed and whether or not the scale has tare deduction and/or computing capability; 

the environment in which the scale will be used; and other factors (not mentioned) should all be a 

part of that decision making process. 

o Because maximum scale division is only one such factor, establishing maximum scale division 

values in HB 44 may have the unintentional effect of restricting an official’s ability to take 

enforcement action on a scale. 

• Unit prices of commodities change over time and new products are continually being brought to 

market, some of which may have a much higher or lower unit price than products currently offered. 

For this reason, it is not possible to specify an acceptable maximum scale division value that will 

render the application of a scale suitable over time. 

• NIST HB 44 already provides the necessary resources (in the way of General Code paragraph GUR.1. Suitability of Equipment and Scales Code paragraph UR.1. Selection Requirements) for 

officials to be able to enforce scale suitability based on the many factors that need to be considered 

at time of inspection. 

• Although the “Old” NIST HB 44 Scales code (i.e., pre-1986) provided maximum scale division 

values based on scale type or design per Table 7b, Applicable to Devices Not Marked with a Class 

Designation, the concept of specifying maximum scale division values for different commodities to 

be weighed on a scale was abolished with the adoption of a new Scales Code in 1986, which bases 

scale selection on a scale’s accuracy class designation. 
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Table 3. Summary of Recommendations

SCL -22.2 – UR.1. Selection Requirements, UR.1.X. Cannabis

V D W A I Notes* Comments

Submitter 

OWM

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

 • A&D Engineering (01-04-

22)

Retailers and 

Consumers

Regulators  • FL Dept Agriculture letter 

of support. (12-07-21)

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:

Amend NIST Handbook 44, Scales Code as follows:

UR.1. Selection Requirements. Equipment shall be suitable for the service in which it is used with 

respect to elements of its design, including but not limited to, its capacity, number of scale divisions, 

value of the scale division or verification scale division, minimum capacity, and computing capability.3

UR.1.X. Cannabis. – The scale division for scales weighing Cannabis shall not exceed:

(a) 0.01g for net weighments up to capacity,

(b) 0.1g for net weighments greater than 10g, up to capacity, and 

(c) 1g for net weighments greater than 100g, up to capacity.

(Added 20XX)
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NIST OWM Detailed Technical Analysis: 

The following was copied from OWM’s 2022 NCWM Interim Meeting analysis and remains little changed 

for the 2022 NCWM Annual Meeting:

We believe this proposal is intended to limit the maximum division value (for three specified net load 

ranges) so that it is sufficiently small that a scale’s round-off error and allowable tolerance is insignificant 

relative to the load being weighed. Although we can understand why some might be in favor of supporting 

such a proposal given its simplicity, we don’t believe it is possible to designate a tiered set of maximum 

division values that will remain relevant over time. A potential problem that we see, and several others 

have already pointed this out in comments made during recent S&T open hearings held during regional 

weights and measures association meetings, is that there’s no way to predict how the use of a scale might 

change over time with respect to the kinds of products weighed or their prices. Consequently, by adopting 

such a proposal one runs the risk of having to be boxed in (i.e., having to accept use of a scale) should over 

time, different products having a much higher unit price be weighed on the scale, or unit prices of products 

weighed on the scale at time of initial scale certification increase significantly to an amount that causes one 

to view the scale’s application unsuitable. 

The value of a scale’s minimum increment is but one factor used to determine the suitability of a scale for 

a particular application, albeit an important one. Other important factors to consider include, but are not 

limited to:

• the smallest and largest load to be weighed 

• the average load to weighed (ideally, the majority of weighing should take place between onequarter and three-quarters of scale capacity) 

• unit prices of commodities weighed and whether or not the scale has computing capability

• dimensions of the load-receiving element 

• special application (e.g., prepack versus direct sale, etc.) 

• scale accuracy class and the HB 44 tolerance to be applied, etc.

• sufficient tare capability

Each of these factors (and others not mentioned) need to be consider when determining whether or not a 

scale is suitable for a particular scale application.

HB 44 already provides the necessary tools (in the way of General Code and Scales Code requirements) for 

officials to be able to enforce suitability. It also provides officials the necessary discretion to decide (at 

time of inspection), based on the many important factors noted above, whether or not a scale is or is not 

suitable for its given application. Rather than proposing changes to HB 44, might the Task Group assigned 

consider developing a scale suitability guide that includes the maximum division value for loads weighed 

as well as other important factors that need to be considered when selecting a scale and distribute it to all 

states? 
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The following are some additional areas of concern that were discussed by members of OWM’s Legal 

Metrology Devices Program in drafting its analysis of this proposal:

• The term “scale division” is specified in the proposed new user requirement paragraph. It is not 

clear if this term was intended to mean scale division (d) or verification scale division (e). Given 

that the value of the scale division (d) is typically ten times smaller than the verification scale 

division (e) on Class I and II scales equipped with different values of (d) and (e), this is a very 

important consideration.

• We question the rationale used to establish the breakpoints of the three tiers proposed. That is, how 

does one justify requiring a division value not to exceed 0.01g for loads up to and including 10 g, 

and yet allow a scale division value ten times greater (i.e., 0.1g) once the load is increased beyond 

a 10g? The same question can be asked for the loads comprised of the next higher breakpoints (i.e., 

0.1g versus 1g). 

• Suitability requirements should be applied independent of the product being weighed. The 

argument to specify maximum permissible scale division values, which correspond to different load 

ranges of cannabis products to be weighed, can be made for other (non-cannabis) commodities. 

• It raises the question, “Why cannabis (and not other products)?” We think adoption of the proposal 

could set a bad precedent in NIST Handbook 44 and possibly lead to additional proposals to 

establish maximum scale division values for other products (e.g., gems, precious metals, meat 

products, etc.), which we view as completely unnecessary. 

Summary of Discussions and Actions:

During the 2022 NCWM Interim meeting, the Committee received somewhat a wide range of comments 

during open hearings. Most who commented supported further development of the item, although there 

were also several questions raised concerning the need for the proposed changes. 

Mr. Doug Musick (Kansas) acknowledged that he agreed with the concept of the proposal while noting too 

that the NCWM had failed to adopt strong standards in that NISI Handbook 44 Scales Code Table 8 

specifies “recommended” minimum loads, making them difficult to enforce. He also noted that HB 44 

already addresses scale suitability and that any proposal should address more than just a single commodity; 

but rather, all products of high cost.

Mr. Evan Foisy (A&D Engineering) read the position statement provided by A&D Engineering to the 

Committee in advance of the 2022 NCWM Interim Meeting as follows:

A&D opposes this item completely and recommends that it be withdrawn. The addition of such specific 

user requirements for a commodity is unprecedented for HB 44. We fail to see the rationale for including 

readability requirements for Cannabis when such requirements have never been required for gold or other 

precious metals with a higher dollar per gram value. 

If the Committee decides that such specifications are warranted, A&D proposes that the requirements be 

changed to 0.01 g for net weighments up to 100 g capacity. The technology exists and is already in use to 

not limit the readability to 0.1 g for capacities from 10 g up to 100 g. Having different accuracy 

requirements for Cannabis consumers who purchase less than 10 g vs. those who purchase more than 10 g 

is not promoting fairness and equity in the market. The maximum that any state allows for a single user 
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purchase is 2.5 oz (approximately 71 g). By offering 100 g x 0.01 g, the entire range of consumer purchases 

will be covered equally and consistently. 

Example: Deli scales allow the same increment size whether you’re getting 1 slice or 10. Cannabis should 

be no different.

The SMA supported continue development of the item with the recommendation that NIST Handbook 44 

Scales Code Table 8 titled “Recommended Minimum Load” be considered in its further development. 

NIST OWM provided the Committee a high-level summary of its analysis of the item, many of the points 

of which questioned not only the need for the proposed change, but also the effect the change (if adopted) 

would have for setting a precedent for producers of other commodities to use in support of making similar 

changes to HB 44 intended to address products they produce. OWM, in its comments to the Committee, 

emphasized that HB 44 already provides the necessary tools (in the way of General Code and Scales Code 

requirements) for officials to be able to enforce scale suitability. It also provides officials the needed 

discretion to decide (at time of inspection), based on the many important factors needing to be considered, 

whether or not a scale is or is not suitable for its given application. OWM recommended, as an alternative 

to the proposal, the development of a scale suitability guide, which should include all important factors 

(and not just scale division value) that need to be considered when determining scale suitability. 

Several who commented before the Committee also questioned use of the term “scale division” in the 

proposal and whether any maximum increments proposed should, instead, be based on “scale verification 

division.” 

In considering the comments received during open hearings, the Committee agreed to maintain the 

“assigned” status of the item.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): put forward to address some issues for cannabis, 

recommend developing - still needs work and continue to work forward.

Mr. Matt Douglas (California - DMS): California supports further development, add non retroactive date -

subsection A states up to capacity... lists suitability requirements based on California, however, this info is 

not a standard. 

Mr. Eric Golden (Cardinal Scales): section A B and C, be better to say 0.1 g for net weighments up to 10 

grams, then B 10 to 100 grams, then C say over 100, etc.

Mr. Kurt Floren (Los Angeles County, California): Mr. Golden stated perfectly what is lacking. There has 

to be ranges put in as to where the graduations are appropriate.

Ms. Erin Sullivan (CO Department of Agriculture): does this pertain to cannabis in any form or 

concentration?
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Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): this is what is going into HB44 - each jurisdiction 

has to define their own. For Oregon, medical is much different than retail. Retail has to abide by this. 

Med. does not. Verbiage in A B and C does need additions.

Ms. Erin Sullivan (CO Department of Agriculture): grows vs. dispensaries? Different products in 

processing facilities are weighed with many containers on the scales. Do states determine the regulation?

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): up to the states to determine how to apply tares 

and increments in which product is weighed.

Mr. Kurt Floren (Los Angeles County, California): cannabis products: later we'll see proposed def. of 

cannabis and cannabis products, are we anticipating the adoption of the proposed language?

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): it is not limited to flowers or bud. Mentions dabs. 

Is there a packaging requirement for the label? Oregon does. There must be a legal for trade scale that can 

prove they are meeting net contents. They must ensure that their process is being executed correctly. He 

thinks this is not limited to flower/bud.

Mr. Kurt Floren (Los Angeles County, California): this raises the point that further consideration needs to 

be put into terms. Brownies, cannabis infused pizza... and other items sold by weight. Are we setting the 

terms for pure cannabis product or are the scales being used for any cannabis containing product?

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): welcomes written input for this topic from anyone. 

Mr. Don Onwiler was a big proponent in this, Mr. Nelson will continue to develop this. 

Mr. Eric Golden (Cardinal Scales): clarification on Mr. Nelson: geared towards net sales, packaging for 

the customer. Is this part of the track and trace program for growers or just for retail?

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): needs to be expanded upon, in Oregon: even the 

growers have to do track and trace. Any scale weight that is used for the cannabis tracking system needs 

to be Weights and Measures compliant. Maybe has to address even a class III scale. They will look more 

into it. 

Mr. Joe Moreo (Ag. Com. Sealer): over time we are going to need one level for concentrates, one for food, 

one for flower, one size fits all will not work. 

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): Agrees that one size does not fit all. This will start 

to give limitations as to what a particular weight will be. Not trying to pigeonhole any device into one 

category, just trying to figure out what works, that’s the intent. 

The WWMA S&T Committee recommends the item be assigned a developmental status so that the 

submitter can continue to work on this as they commented during open hearings. 

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, Mr. Russ Vires, SMA, stated that they have no position 

on this item at this time. 
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Mr. Matt Curran, State of Florida, stated that he supports this as a Voting item. He also provided comments 

in support of this item from Mr. Eric Golden, Cardinal Scale. Cardinal offered some changes as well. The 

suggested changes are as follows: 

UR.1.X. Cannabis. – The scale division for scales weighing Cannabis shall not exceed: 

(a) 0.01 g for net weighments up to capacity up to 10g, 

(b) 0.1 g for net weighments greater than 10g, up to 100g, capacity, and 

(c) 1 g for net weighments greater than 100g, up to capacity. 

(Added 20XX) 

Mr. Charlie Rutherford (Cannabis Committee) stated that he supports this item moving forward as a voting 

item with the changes suggested by Cardinal Scale and Dr. Curran. 

This Committee recommends that this item be moved forward as a Voting item if the changes suggested 

above are made. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Eric Golden (Cardinal Scale) made suggestions to change the language in this item to the following:

UR.1.X Cannabis......... 

(a) 0.01g for net weighments up to 10 g

(b) 0.1g for net weighments greater that 10g , up to 100 g, and

(c) 1 g for net weighments greater than 100g , up to capacity

Mr. Lou Sakin (Hopkinton/Northbridge, Massachusetts) commented that he agrees with changes above. 

 

Discussions were heard regarding the agreement with table 8 in scale code as this requirement is more 

restrictive than table 8 parameters.

Mr. Eric Golden (Cardinal Scale) commented that national uniformity would be good and many states have 

informational publications that outline requirements in their state for Cannabis scale requirements.

Mr. Jimmy Cassidy (Massachusetts) recommends voting status with the changes above.

Mr. Matt Curran (Florida) commented that harmonization with table 8 would be a good idea if possible.

Mr. Lou Sakin (Hopkinton/Northbridge, Massachusetts) questioned if Cannabis should be in italics. The 

Committee suggests making the change to italics for Cannabis. 

The NEWMA Specifications and Tolerances Committee recommends that this item be given Voting Status 

with suggested edits.
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During the 2022 Annual Meeting Open Hearings the following comments were heard:

Mr. James Cassidy (Massachusetts) commented as the Co-Chair of the NCWM Cannabis Task Group. He 

supported the assigned status so the task group can continue to develop the item from comments received 

at the 2022 Interim. Mr. Russ Vires (SMA) supported continued development and indicated that a user 

requirement typically does not pertain to a specific commodity. Mr. Vires suggested the words “retail 

cannabis” should be added to the “Class II” section of Table 7a and the words “bulk cannabis processing 

and sales” should be added to the “Class III” section of Table 7a. Mrs. Tina Butcher (NIST OWM) read 

the following statement: “As a non-regulatory metrology institute, NIST defers to federal agencies with 

regulatory authority under the Controlled Substances Act (CSA) for the scheduling of drugs or other 

substances. NIST does not have a policy role related to the production, sale, distribution, or use of cannabis 

(including hemp and marijuana). While the 2018 Farm Bill removed hemp from the list of controlled 

substances under Schedule 1 of the CSA, marijuana remains on that list. NIST must respect that distinction 

even as it exercises its statutory authority to develop and disseminate national weights and measures 

standards for the production, distribution, and sale of products in the commercial marketplace. NIST 

remains committed to providing technical assistance to the weights and measures community. OWM has 

provided key technical points for the community to consider in its deliberations of cannabis-related 

proposals, and OWM would be happy to provide any necessary clarification. OWM comments are intended 

to encourage technically sound application of legal metrology laws, regulations, and practices to the 

measurement and sale of these products.”

After hearing comments from the floor, the Committee recognized the need for further development of the 

item and recommended that the item retain an Assigned status. The Committee recommends the NCWM 

Cannabis Task Group work with the SMA and other stakeholders to further develop this item. 

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing, the Committee heard comments from the floor. Mr. Loren 

Minnich (Kansas) stated he’s not sure of the intent and that it needs more developing. Mr. Eric Golden

(Cardinal Scales) agreed with Mr. Golden, is it “e” or “d”, will send notes to Committee. Mr. Ivan Hankins

(Iowa) would support item with Mr. Golden’s language. Mr. Golden continued by recommending the 

following change to which will add clarity to the listed weight ranges in SCL22.2 (in red) 

SCL-22.2 UR.1. Selection Requirements, UR.1.X. Cannabis 

UR.1.X. Cannabis. – The scale division verification scale interval, e, for scales weighing Cannabis 

shall not exceed:

(d) 0.01g for net weighments up to capacity up to 10g, 

(e) 0.1g for net weighments greater than 10g, up to 100g, capacity, and

(f) 1g for net weighments greater than 100g, up to capacity.

(Added 20XX)

CWMA S&T Committee recommends as voting item with the proposed changes from Cardinal Scales.

During the 2022 Annual Meeting Open Hearings the following comments were heard: 

Mr. Doug Musick (Kansas) welcomed the attempt to define suitability; recommended the following:
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SCL-22.2 UR.1. Selection Requirements, UR.1.X. Cannabis

UR.1.X. Cannabis. – A retail Cannabis scale shall not be used to weigh net loads smaller than 100 displayed 

scale divisions “d”,

(a) 0.01g for net weighments 10g or less,

(b) 0.1g for net weighments greater than 10g and up to 100g, and

(c) 1g for net weighments greater than 100g.

(Added 20XX)

Mr. Russ Vires (SMA): The addition of a User Requirement is not the best approach in this situation; User

Requirements do not typically apply to a specific commodity. Supported continuing as developing and the 

following proposed changes should be considered instead:

- The words “retail cannabis” should be added to the “Class II” section of Table 7a.

- The words “bulk cannabis processing and sales” should be added to the “Class III”

section of Table 7a.

Mr. Charlie Stutesman (Kansas) questioned why only metric units are referenced and not also include inchpound units.

The CWMA S&T Committee recommends this item remain with the NCWM Cannabis Task Group and 

that the suggested changes are considered.

SMA

During the 2021 Fall Meeting, the SMA supported the continued development of this item.

During the 2022 Spring Meeting, the SMA supported the continued development of this item.

Rationale: The addition of a User Requirement is not the best approach in this situation; User Requirements 

do not typically apply to a specific commodity. The following proposed changes should be considered 

instead:

• The words “retail cannabis” should be added to the “Class II” section of Table 7a.

• The words “bulk cannabis processing and sales” should be added to the “Class III” section of Table 

7a.

LMD – LIQUID MEASURING DEVICES

LMD-21.1 V Table S.2.2. Categories of Device and Method of Sealing

Source: Gilbarco, Inc.
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Purpose and Justification:

To modify Category 3 requirements under Methods of Sealing to allow electronic copy of event logger for 

liquid measuring devices. To enhance or have alternate wording to existing Item LMD-20.1 under review 

for this item.

Current requirement is that category 3 device must have printed copy made available on site for the event 

logger information. Category 3 devices are fully connected electronic devices here in the modern age and 

thus we need to move away from the archaic requirement of only allowing a paper copy for this item. The 

industry fully supports this change. LMD’s have many types of regulatory events that accumulate in the 

event logger: blend ratio changes, calibration changes for the meters, SW downloads are examples. Often 

our only available print option is through the device receipt printer. With its tiny width of receipt paper, 

the event log for an older liquid measuring device will be several feet long and have text that wraps and is 

difficult to read. Allowing an electronic copy will be more convenient, easily read, and easily 

saved/retained/shareable.

Wayne Fueling Systems, LLC had a current proposal, Item LMD-20.1 for this item and in discussion with 

him he has been very supportive of me providing alternate wording above for consideration, or possibly to 

use in place of his proposal. Hopefully we can hear from Wayne Fueling Systems on this in the upcoming 

meetings. Also, I am aware of the Electric vehicle charger industry is working on this item to propose 

allow electronic copy as well.

The submitter requested voting status for this item in 2021.

OWM Executive Summary for LMD-21.1 – Table S.2.2. Categories of Device and 

Method of Sealing

OWM Recommendation: OWM concurs with the direction toward permitting an electronic form of 

the event log, provided the following key issues that have been raised in discussions are addressed.

o Event Log Information Accessible During the Inspection. Inspectors need this information in order 

to assess the disposition of a device during the inspection process, not at a later point in time.

o IT Security Concerns with Connection Method. Options suggesting use of a memory stick or wired 

interface with a mobile device may pose a deterrent since many jurisdictions’ IT security policies 

would not permit this method of accessing information on a jurisdiction-owned mobile device.

o Availability of Mobile Devices. Not all inspectors are equipped with mobile devices for 

downloading and viewing information.

o (Larger) Electronic Display on Site. Might another alternative be to provide an on-site, inspectoraccessible display which meets minimum dimensions? This option might be considered a 

compromise in which the inspector could easily access and view the information, though it does 

create a potential problem and disadvantage in not facilitating the recording and retaining of the 

results as part of the inspection record.

o Security of Event Logger Data. A point raised in discussions of this issue was how an inspector 

can determine if information downloaded electronically is connected with the specific device under 

inspection. Revisions to the current requirements need to consider including information with any 

remotely-downloaded log that would enable the inspector to link the log to the specific device.
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OWM Executive Summary for LMD-21.1 – Table S.2.2. Categories of Device and 

Method of Sealing

• It is not clear that the current proposal has addressed all of these items. Should the proposal move 

forward as written, it will be important at minimum that these items be considered during type 

evaluation and followed up during field inspection to ensure that the above items are addressed. 

• While the ultimate goal is to move in the direction of the electronic form, not all jurisdictions may 

have the capability of viewing an electronic version of the event log at the time of inspection. Most 

people seem to be supportive of the concept of electronic versions of the information and want to 

move in that direction; however, it is essential that inspectors be able to gain the information needed 

for an inspection in a form accessible at the time of the inspection. An inspector needs to have 

access to this information on site, for example if the information is transmitted, how will the 

inspector view the information on site if they do not have electronic capability to do so? The use of 

General Code requirement G-UR.2.3 Accessibility for Inspection, Testing, and Sealing Purposes 

and G-UR.4.4. Assistance in Testing Operations may be used but may not be apparent to all 

inspectors.

• Similar language was adopted into the Electric Vehicle Fueling Systems tentative code. 

• As language is adopted in NIST HB 44 to accept an electronic copy of the sealing information, 

consideration should be given to making appropriate changes to the sealing requirements for other 

devices in NIST HB 44.

Table 3. Summary of Recommendations

LMD-21.1 Table S.2.2. Categories of Device and Method of Sealing

V D W A I Notes* Comments

Submitter 

OWM

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers
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Table 3. Summary of Recommendations

LMD-21.1 Table S.2.2. Categories of Device and Method of Sealing

V D W A I Notes* Comments

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Liquid Measuring Devices Code as follows:

Table S.2.2.

Categories of Device and Methods of Sealing

Categories of Device Methods of Sealing

Category 1: No remote configuration capability. Seal by physical seal or two event counters: one for 

calibration parameters and one for configuration 

parameters.

Category 2: Remote configuration capability, but 

access is controlled by physical hardware.

The device shall clearly indicate that it is in the 

remote configuration mode and record such message 

if capable of printing in this mode or shall not operate 

while in this mode.

[The hardware enabling access for remote 

communication must be on-site. The hardware must 

be sealed using a physical seal or an event counter 

for calibration parameters and an event counter for 

configuration parameters. The event counters may 

be located either at the individual measuring device 

or at the system controller; however, an adequate 

number of counters must be provided to monitor the 

calibration and configuration parameters of the 

individual devices at a location. If the counters are 

located in the system controller rather than at the 

individual device, means must be provided to 

generate a hard copy of the information through an 

on-site device.]*

[*Nonretroactive as of January 1, 1996]
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NIST OWM Detailed Technical Analysis:

NIST OWM previously provided comments to this item which was a Block item that included LMD 20.1 

and LMD 21.1. Both items addressed the allowance of an electronic log in lieu of a printed copy of an 

audit trail for category three method of sealing in the liquid measuring devices code. 

Initially, the submitter of LMD-20.1, Randy Moses, Wayne Fueling Systems, LLC requested this item be 

withdrawn based on concerns raised during discussions at the 2019 NTEP Measuring Sector Meeting. In 

January 2020, however, Mr. Moses retracted that request.

During the 2021 NCWM Interim Meeting work session, the Committee agreed to withdraw LMD-20.1 and 

agreed that the submitter of LMD-20.1, Wayne Fueling Systems, LLC, will work with the Submitter of 

LMD-21.1, Gilbarco, to develop one proposal to allow electronic logs for Category 3 sealing requirements. 

The Committee agreed on a Developing status for LMD-21.1. 

OWM met with Gilbarco in 2021 to discuss the proposed changes and concurs with the direction toward 

permitting an electronic form of the event log, provided the following key issues that have been raised in 

discussions are addressed.

OWM recognizes the desire to move forward with electronic forms of required information and believes 

this is an appropriate direction in which to head. A key question the Committee must consider is what 

alternatives may need to be offered as we move in this direction to ensure that officials have adequate 

information to make enforcement decisions at the time of an inspection.

• OWM offers no opposition to the proposal but suggests the community revisit past discussions to ensure 

that the issues raise during those discussions are no longer of concern.

Category 3: Remote configuration capability access 

may be unlimited or controlled through a software 

switch (e.g., password). 

[Nonretroactive as of January 1, 1995]

The device shall clearly indicate that it is in the 

remote configuration mode and record such message 

if capable of printing in this mode or shall not operate 

while in this mode.

[Nonretroactive as of January 1, 2001]

An event logger is required in the device; it must 

include an event counter (000 to 999), the parameter 

ID, the date and time of the change, and the new 

value of the parameter. A printed copy of the 

information must be available on demand 

through the device or through another on-site 

device. The information may also be available 

electronically. The event logger information shall 

be available at the time of inspection either as a 

printed copy or in electronic format. The 

information may be printed by the device, printed 

by another on site device, or transmitted 

electronically. The event logger shall have a 

capacity to retain records equal to 10 times the 

number of sealable parameters in the device, but not 

more than 1000 records are required. (Note: Does not 

require 1000 changes to be stored for each 

parameter.)

[Nonretroactive as of January 1, 1995]

(Table Added 1993) (Amended 1995, 1998, 1999, 2006, and 2015)
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• In assessing this item, although G-S.5.6. refers to printed receipts and tickets, the Committee will want 

to consider some of the rationale and discussion surrounding the changes made to G-S.5.6. Recorded 

Representations in 2014 (also referenced by the submitter) to determine whether or not the points raised 

in the past with regard to providing required information to the official in only an electronic form will 

meet the needs of the regulators.

• During discussions of G-S.5.6. concerns raised within the regulatory community included the 

inspector’s lack of access to the internet (e.g., when no internet service available in a given area or the 

inspector has no means to access the internet or is not permitted to insert digital media from an external 

source into his or her computer. Some comments heard by the Committee during these discussions 

indicated that inspectors sometimes don’t have email or have access to it on site and the information 

from an event logger is typically needed at the time of inspection in order to make an enforcement 

decision.

• While the ultimate goal is to move in the direction of the electronic form, not all jurisdictions may have 

the capability of viewing an electronic version of the event log at the time of inspection. Most people 

seem to be supportive of the concept of electronic versions of the information and want to move in that 

direction; however, it is essential that inspectors be able to gain the information needed for an inspection 

in a form accessible at the time of the inspection. An inspector needs to have access to this information 

on site.

• At the 2020 Interim Meeting, Mr. Brent Price (Gilbarco) recommended a Voting or Developing status 

for this item and offered to work with the submitter. Mr. Price noted that the Category 3 devices coming 

into the market are able to print an event log, but the font is quite small.

• Given the requirement for ensuring event logger information is readable and readily understandable, 

OWM noted suggestions to use a narrow receipt (such as is provided with “Card Readers in 

Dispensers”) as the means for printing an event log may not meet requirements for clarity and legibility 

if printed in an extremely small font.

• Some members of industry (LC, FMC) and the regulatory community (Alaska, Oregon, California, 

New York) support the concept of an electronic version of the required event log on a Category 3 

device, but noted the proposal requires additional work.

• Mr. Jim Pettinato (Technip FMC) noted the Software Sector also supports an electronic log and 

suggested a user requirement may also be warranted.

• OWM concurs with the direction toward permitting an electronic form of the event log, provided the 

following key issues that have been raised in discussions are addressed:

o Event Log Information Accessible During the Inspection. Inspectors need this information in 

order to assess the disposition of a device during the inspection process, not at a later point in time.

o IT Security Concerns with Connection Method. Options suggesting use of a memory stick or 

wired interface with a mobile device may pose a deterrent since many jurisdictions’ IT security 

policies would not permit this method of accessing information on a jurisdiction-owned mobile 

device.
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o Availability of Mobile Devices. Not all inspectors are equipped with mobile devices for 

downloading and viewing information.

o (Larger) Electronic Display on Site. Might another alternative be to provide an on-site, inspectoraccessible display which meets minimum dimensions? This option might be considered a 

compromise in which the inspector could easily access and view the information, though it does 

create a potential problem and disadvantage in not facilitating the recording and retaining of the 

results as part of the inspection record.

o Security of Event Logger Data. A point raised in discussions of this issue was how an inspector 

can determine if information downloaded electronically is connected with the specific device under 

inspection. Revisions to the current requirements need to consider including information with any 

remotely-downloaded log that would enable the inspector to link the log to the specific device.

• OWM also concurs with the Committee’s suggestion for the submitter to focus on the format of an 

electronic display of the event log and any barriers to its access (as noted above).

• OWM further asks jurisdictions to consider whether they are actively inspecting and viewing event 

counter and event logger information. Experience reviewing event counter and logger information will 

help regulators make a better-informed decision on any alternatives proposed.

• OWM notes that device types that are activated and/or operated using mobile applications may already 

be providing some flexibility in this regard (see 5.60 TNMS Code S.2.3. Change Tracking, p.5-104).

• Similar language was adopted into the EVF tentative code. 

• As language is adopted in NIST HB 44 to accept an electronic copy of the sealing information, 

consideration should be given to making appropriate changes to the sealing requirements for other 

devices in NIST HB 44.

Summary of Discussions and Actions:

The Committee agreed at the 2021 Interim Meeting to withdraw LMD-20.1. The Committee agreed on a 

Developing status for LMD-21.1 and at this meeting the item was assigned to the following persons for 

further development. For more information or to provide comment, please contact:

Mr. Brent Price

Gilbarco Inc.

(336) 547-5009 

brent.price@gilbarco.com

Mr. Randy Moses

Wayne Fueling Systems, LLC

(215) 257-2759

At the NCWM 2022 Interim Meeting open hearings the submitter of this item noted that this proposal will 

allow an electronic copy of category 3 event loggers and also noted that this was adopted into the EVF 

tentative code. The submitter requested a voting status for this item. Several States were in support of a 

Voting status for this item. An industry representative was also in support of a Voting status for this item. 

The Committee agreed to a Voting Status for this item.
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Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Brent Price (Gilbarco), submitter: to modify event logger for cat. 3 devices - will allow electronic copy 

to be available to W/M and not just hard copy. Worked with Wayne to develop this, conferenced with 

NIST and they are supportive. EV systems allows for this. We ask to allow LMD allow this (like EV). 

Has support of industry. Wants to consider this for Voting status.

The WWMA S&T Committee recommends this item be assigned a Voting status.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, Mr. Brent Price (Gilbarco) who is the submitter of this 

item, stated that the EVF code was recently changed to allow electronic copies of the event logger, and that 

he supports moving this forward as a Voting Item. 

Mr. Tim Chesser (Arkansas) supported moving this forward as a Voting Item.

This Committee recommends moving this item forward as a Voting Item. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Jim Willis (New York) and Mr. John McGuire (New Jersey) commented to recommend Voting status.

The NEWMA Specifications and Tolerances Committee recommends that this item be given Voting status.

During the 2022 Annual Meeting Open Hearing Mr. Brent Price (Gilbarco) and Mr. Jim Willis (New York) 

commented that they support an electronic format of event loggers.

After hearing comments from the floor, the Committee considered the item to be fully developed and 

recommended that the item retains Voting status. 

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing, the Committee heard comments from the floor. Ms. Diane 

Lee (NIST OWM) said this item is ready to move forward as a Voting or remain Developing item. Mr. 

Charles Stutesman (Kansas) said the item is read for vote.

CWMA S&T Committee recommends that the item move forward as Voting.

During the 2022 Annual Meeting, Open Hearing Mr. Brent Price (Gilbarco): on behalf of Gilbarco and 

industry, appreciate the support to allow electronic format for event logger. Printed copy on site is difficult 

when the system doesn’t contain printers. Taxi meters and EVSE allow digital versions of event logger.

The CWMA S&T Committee recommends this item to remain a Voting item.
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LMD-22.1 V Table T.2. Accuracy Classes and Tolerances for Liquid Measuring Devices Covered 

in NIST Handbook 44, Section 3.30

(Note: This item was submitted to the NCWM by the November 1, 2021 deadline for item submission for 

items submitted directly by NCWM committees and other work groups. However, the item was not 

submitted in time for it to be considered at the fall 2021 regional weights and measures association 

meetings.)

Source: NTEP Measuring Sector

Purpose and Justification:

To correct an inconsistency between the application of tolerances to smaller capacity Diesel Exhaust Fluid 

(DEF) measuring systems and retail motor-fuel dispensers.

OWM Executive Summary for LMD-22.1 – Table T.2. Accuracy Classes and Tolerances

for Liquid Measuring Devices Covered in NIST Handbook 44, Section 3.30

OWM Recommendation: OWM believes this item is ready for a vote as proposed.

• During a review of NTEP requirements related to DEF dispensing systems, the NTEP Measuring 

Sector observed an inconsistency between the application of NIST Handbook 44.tolerances for retail 

motor-fuel dispensers (RMFDs) and for small capacity DEF measuring systems. 

• Smaller capacity DEF measuring systems use measuring equipment nearly identical to that used for 

RMFDs.

o Though DEF is not a motor fuel, NCWM and NTEP have agreed in past discussions to treat 

these systems the same.

o Most inspectors have treated them essentially the same for some years.

o Given the properties of the product being measured and the capabilities of the dispensing 

equipment, OWM concurs with this approach.

• As presently written, Table T.2. specifies a different tolerance for special tests of DEF dispensers 

than would be used for RFMDs.

o Without specific clarification in Table T.2, there is a potential for inconsistently applying 

tolerances to DEF dispensers.

• OWM concurs the proposed change to Footnote 1 will:

o correct the oversight made when DEF dispensers were added to requirements;

o will align the special test tolerances for DEF dispensers with that of RMFDs; and

o will eliminate the potential which currently exists for inconsistent application of tolerances.
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OWM Executive Summary for LMD-22.1 – Table T.2. Accuracy Classes and Tolerances

for Liquid Measuring Devices Covered in NIST Handbook 44, Section 3.30 

• Although this item was submitted too late for the regional associations to review in fall 2021, OWM 

concurs with the Measuring Sector’s recommendation to designate this as a Voting item for 2022. 

This is based on:

o the approach used by NTEP for many years to treat DEF and RMFDs consistently;

o consistency among current requirements in NIST HB 44 for the two applications; and

o feedback OWM has had over the years regarding how some weights and measures jurisdictions 

approach DEF systems relative to RMFDs.

• This is further supported by the support of the CWMA and NEWMA at their Spring 2022 annual 

meetings.

Table 3. Summary of Recommendations

LMD-22.1 Table T.2. Accuracy Classes and Tolerances for Liquid Measuring Devices Covered in 

NIST Handbook 44, Section 3.30

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 4

SWMA 4

NEWMA  4

CWMA  4

NCWM

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:
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Amend Handbook 44, Liquid-Measuring Devices Code as follows:

Table T.2. 

Accuracy Classes and Tolerances for Liquid Measuring Devices Covered in

NIST Handbook 44, Section 3.30.

Accuracy 

Class Application AcceptanceTolerance

Maintenance

Tolerance

Special 

Test 

Tolerance1

0.3

- Petroleum products delivered from 

large capacity (flow rates greater than 

115 L/min or 30 gpm)** devices, 

including motor-fuel devices

- Heated products (other than asphalt) 

at temperatures greater than 50 °C 

(122 °F)

- Asphalt at temperatures equal to or 

below 50 °C (122 °F)

- All other liquids not shown in the 

table where the typical delivery is 

over 200 L (50 gal)

0.2 % 0.3 % 0.5 %

0.3A - Asphalt at temperatures greater than 

50 °C (122 °F) 0.3 % 0.3 % 0.5 %

0.5*

- Petroleum products delivered from 

small capacity (at 4 L/min (1 gpm) 

through 115 L/min or 30 gpm)** 

motor-fuel devices

- Agri-chemical liquids

- All other applications not shown in 

the table where the typical delivery is 

≤ 200 L (50 gal)

0.3 % 0.5 % 0.5 %

1.1

- Petroleum products and other normal 

liquids from devices with flow rates** 

less than 1 gpm.

- Devices designed to deliver less than 

1 gal

0.75 % 1.0 % 1.25 %

* For test drafts ≤ 40 L or 10 gal, the tolerances specified for Accuracy Class 0.5 in the table above do 

not apply. For these test drafts, the following applies:

(a) Maintenance tolerances on normal and special tests shall be 20 mL plus 4 mL per indicated liter 

or 1 in3 plus 1 in3 per indicated gallon.
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NIST OWM Detailed Technical Analysis:

• During a review of NTEP requirements related to DEF dispensing systems, the NTEP Measuring Sector 

observed an inconsistency between the application of NIST Handbook 44tolerances for retail motorfuel dispensers (RMFDs) and for small capacity DEF measuring systems.

o As presently written, Table T.2. specifies a different tolerance for special tests of DEF 

dispensers than would be used for RFMDs.

• Based on discussions with some weights and measures jurisdictions and discussions at Measuring 

Sector meetings, OWM is not certain if the tolerances presently specified in Table T.2. for special tests 

are being consistently applied.

• Smaller capacity DEF measuring systems use measuring equipment nearly identical to that used for 

RMFDs.

o Though DEF is not a motor fuel, NCWM and NTEP have agreed in past discussions to treat 

these systems the same, both in NIST HB 44 requirements and in type evaluation.

o Given the properties of the product being measured and the capabilities of the dispensing 

equipment, OWM concurs with this approach.

• OWM concurs the proposed change to Footnote 1 will correct the oversight made when DEF dispensers 

were added to requirements and align the special test tolerances for DEF dispensers with that of 

RMFDs.

• Although this item was submitted too late for the regional associations to review in fall 2021, OWM 

concurs with the Measuring Sector’s recommendation to designate this as a Voting item for 2022. This 

is based on:

o the approach used by NTEP for many years to treat DEF and RMFDs consistently;

o consistency among current requirements in NIST HB 44 for the two applications; and

o feedback OWM has had over the years regarding how some weights and measures jurisdictions 

approach DEF systems relative to RMFDs.

(b) Acceptance tolerances on normal and special tests shall be one-half the maintenance tolerance 

values.

1 Special test tolerances are not applicable to retail motor fuel and retail DEF dispensers.

** Flow rate refers to designed or marked maximum flow rate.

(Added 2002) (Amended 2006 and 2013)
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Summary of Discussions and Actions:

During the review of NTEP requirements related to DEF dispensing systems, the NTEP Measuring Sector 

observed an inconsistency between the application of tolerances for retail motor-fuel dispensers (RMFDs) 

and for small capacity DEF measuring systems.

Smaller capacity DEF measuring systems use measuring equipment nearly identical to that used for RMFD 

applications and the NCWM and NTEP have agreed in past discussions that these two applications should 

be addressed consistently. Changes were made to NIST Handbook 44 in 2019 to more closely align 

requirements for RMFDs and smaller capacity DEF measuring systems; for example, paragraph N.4.2.2. 

Retail Motor-Fuel Devices and DEF, which specifies identical special test procedures for both systems. 

However, Table T.2. Accuracy Classes and Tolerances for Liquid-Measuring Devices Covered in NIST 

Handbook 44, includes an inconsistency in the application of tolerances for the “special test” for these two 

applications

It was judged during the Measuring Sector’s review that, based upon the application flow rates, without the 

note a DEF dispenser would be given a different tolerance for special tests than would RMFDs.

The proposed change to Footnote 1 will correct the oversight made when DEF dispensers were added to 

requirements in alignment with retail motor-fuel devices.

The submitter requested that this be a Voting item in 2022.

At the 2022 NCWM Interim Meeting, the Committee recommended the item under consideration be given 

a Voting status with the addition of the word “retail” in front of DEF to add clarity to the code.

Regional Association Reporting:

Western Weights and Measures Association

At the WWMA 2021 Annual Meeting, this item was not submitted to the Fall 2021 regional weights and 

measures associations.

Southern Weights and Measures Association

At the SWMA 2021 Annual Meeting, this item was not submitted to the Fall 2021 regional weights and 

measures associations.

Northeastern Weights and Measures Association

At the NEWMA 2021 Interim Meeting, this item was not submitted to the Fall 2021 regional weights and 

measures associations.

During the 2022 NEWMA Annual Meeting, NEWMA heard comments from Mr. Brent Price (Gilbarco) 

stating he supported the item as it adds clarity for tolerances for DEF. Mrs. Tina Butcher (NIST OWM) 

commented that this item originated in the Measuring Sector and identified this as a house keeping item as 

DEF dispensers are often designed and treated as RMFDs. Therefore, the tolerance table for RMFD on 

special test tolerances will be updated to include DEF.
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After hearing comments from the floor, the NEWMA S&T Committee considered the item to be fully 

developed and recommended that the item retains a Voting status. 

Central Weights and Measures Association 

At the CWMA 2021 Interim Meeting, this item was not submitted to the Fall 2021 regional weights and 

measures associations.

During the CWMA 2022 Annual Meeting, the CWMA heard comments from Mr. Michael Keilty 

(Endress+Hauser, Chair of NTEP Measuring Sector) who noted the possibility of confusion that would 

allow retail DEF dispensers to have a different tolerance and recommended moving this forward as voting 

item. Mr. Brent Price (Gilbarco) supported the item. When DEF dispensers were built, they built them 

along the same guidelines as RMFD. This provides clarity.

The CWMA S&T Committee recommends this item to remain a Voting item.

VTM – VEHICLE TANK METERS

VTM-18.1 V S.3.1 Diversion of Measured Liquid and S.3.1.1. Means for Clearing the Discharge 

Hose and UR.2.6. Clearing the Discharge on a multiple-product, single discharge 

hose. 

(NOTE: At the 2020 Interim Meeting the Committee agreed to combine both VTM-18.1 and VTM-20.1. 

Both items are now one item under VTM-18.1.)

Source:

New York and NIST OWM (Carryover from 2018, VTM 1-B) and Murray Equipment, Inc., Total Control 

Systems

Purpose and Justification:

Provide specifications and user requirements for manifold flush systems on a multiple-product, singledischarge hose. Recognize that there is a balance between a mechanism that provides an important safety 

benefit but also, if used incorrectly, facilitates fraud. Ensure that VTM owners understand their 

responsibilities when installing such a system and ensure uniformity in enforcement throughout the country 

and clarify the paragraph to protect vehicle motor fuel quality, retain safe operating procedures when 

handling vehicle motor fuels, and to prevent fraud during delivery of vehicle motor fuels from vehicle tank 

meters.

OWM Executive Summary for VTM-18.1 – S.3.1 Diversion of Measured Liquid and 

S.3.1.1. Means for Clearing the Discharge Hose and UR.2.6. Clearing the Discharge on a 

multiple-product, single discharge hose.

OWM Recommendation: OWM believes the proposed changes represent a reasonable solution that 

will help minimize the potential for fraud with the use of manifold flush systems while allowing 

companies access to the safety-related benefits from the use of such systems in distributing products on 

VTMs. With the most recent version of the Item under Consideration, OWM believes this item is ready 

for vote.
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OWM Executive Summary for VTM-18.1 – S.3.1 Diversion of Measured Liquid and 

S.3.1.1. Means for Clearing the Discharge Hose and UR.2.6. Clearing the Discharge on a 

multiple-product, single discharge hose.

o A manifold flush system allows liquid to be diverted from the discharge line on single hose multiproduct VTMs so that liquid of one product is not mixed with liquid of another in the discharge line.

o NIST Handbook 44 already includes provisions allowing the use of manifold flush systems.

 However, without appropriate safeguards, these systems represent a significant potential for 

fraud.

 OWM believes the current Item under Consideration offers additional safeguards that are not 

present in the current NIST HB 44 language.

 These changes will reduce the potential for facilitation of fraud with the design and use of these 

devices.

o When presented for a vote in 2019, this item (though revised multiple times in response to comments) 

failed to obtain sufficient votes to “pass” or “fail” and was returned to Committee.

 Several additional variations to address comments and concerns were subsequently considered. 

o In January 2020, this item was combined with a related Item VTM-20.1 (which proposed limits on 

the use of these systems with specific product types) with the goal of having the submitters of both 

items work together to reach a reasonable compromise between the two proposals.

o Since January 2020, the submitters of both items have worked to find a compromise that best meets 

the needs of the community.

o In developing the current proposal, the submitters considered concerns raised regarding the use of 

these systems, including:

 the potential for facilitation of fraud with the use of these systems;

 the potential for cross contamination of products in different tank compartments; and

 the suitability of using a single meter for multiple product types.

o These concerns were balanced against comments indicating:

 these same product handling practices have occurred for many years without the use of such 

systems; and

 manifold flush systems can offer distinct safety advantages for drivers when flushing product.

o OWM continues to have concerns regarding the safety of delivering products such as gasoline and 

home heating oil through the same meter (and questions whether a single meter is suitable for such 

purposes)
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OWM Executive Summary for VTM-18.1 – S.3.1 Diversion of Measured Liquid and 

S.3.1.1. Means for Clearing the Discharge Hose and UR.2.6. Clearing the Discharge on a 

multiple-product, single discharge hose.

 However, OWM recognizes this is already a widespread practice in the industry and placing a 

blanket limitation in NIST Handbook 44 may not best serve the community.

o OWM acknowledges the safety advantages of such a systems to the drivers since the drivers do not 

have to climb on top of the VTM truck to flush product from the line before delivering another 

product.

o OWM notes that such changes do not preclude a jurisdiction from implementing policies regarding 

the use of a single meter to dispense multiple different product types.

Table 3. Summary of Recommendations

VTM-18.1 - S.3.1 Diversion of Measured Liquid and S.3.1.1. Means for Clearing the Discharge 

Hose and UR.2.6. Clearing the Discharge on a multiple-product, single discharge hose.

V D W A I Notes* Comments

Submitter 

OWM  Email comments NIST OWM (01-04-21)

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Comments

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Vehicle-Tank Meters Code as follows: 
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S.3.1. Diversion of Measured Liquid. – No means shall be provided by which any measured liquid can 

be diverted from the measuring chamber of the meter or the discharge line thereof. However, two or 

more delivery outlets may be installed if means are provided to ensure that:

(a) liquid can flow from only one such outlet at one time; and

(b) the direction of flow for which the mechanism may be set at any time is definitely and 

conspicuously indicated.

This paragraph does not apply to the following:

(1) Equipment used exclusively for fueling aircraft.

(2) Multiple-product, single-discharge hose metering systems that are equipped with systems 

designed to flush the discharge hose, provided the flushing system complies with the 

provisions of paragraph S.3.1.1. Means for Clearing the Discharge Hose, MultipleProduct, Single-Discharge Hose Metering Systems. 

(Amended 2018 and 20XX) 

S.3.1.1. Means for Clearing the Discharge Hose, Multiple-Product, Single-Discharge Hose 

Metering Systems. - Multiple-product, single-discharge hose Mmetering systems may be 

equipped with systems specifically designed to facilitate clearing of the discharge hose prior to 

delivery to avoid product contamination. In such systems. a valve to temporarily divert product 

from the measuring chamber of the meter to a storage tank, shall be installed only if all the 

following are met:

(a) the discharge hose remains of the wet-hose type; 

(b) the valve and associated piping are approved by the weights and measures authority having

jurisdiction over the device prior to commercial use; 

(c) the valve is permanently marked with its purpose (e.g., flush valve); 

(d) the valve is installed in a conspicuous manner and as far from the hose reel as practical; 

(e) the system clearly and automatically indicates the direction of product flow during 

operation of the flush system; and

(f) clear means, such as an indicator light or audible alarm, is used to identify when the valve 

is in use on both quantity indications and any associated recorded representations (e.g., 

using such terms as “flushing mode” or “not for commercial use”);

[Nonretroactive as of January 1, 2024]

(g) effective, automatic means shall be provided to prevent passage of liquid through any 

such flush system during normal operation of the measuring system; and

[Nonretroactive as of January 1, 2024] 

(h) no hoses or piping are connected to the inlet when it is not in use. 

(Added 2018) (Amended 20XX)
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UR.2.6. Clearing the Discharge Hose.

UR.2.6.1. Clearing the Discharge Hose, General. – A manifold flush or similar system 

designed to accommodate the flushing of product on single-hose, multiple-product systems is 

not to be used during a commercial transaction. The following restrictions apply:

(a) The inlet valves for the system are not to be connected to any hose or piping (dust 

covers are permitted) when not in use.

(b) When the flushing system is in operation, the discharge hose is only to be connected 

to the port for the product type being flushed from the discharge line.

(c) Following the flushing process, indications and recording elements must be reset to 

zero prior to beginning a commercial delivery.

(Added 20XX)

UR.2.6.2. Minimizing Cross Contamination. – When dissimilar products are dispensed 

through a single meter, the user shall take steps to ensure the system is properly flushed to 

minimize the potential for cross contamination of product in receiving tanks on subsequent 

deliveries. Dispensing products having radically different characteristics (e.g., gasoline and 

diesel fuel) through a single meter delivery system is not recommended.

(Added 20XX)

UR.2.6.3. Records. Whenever, prior to delivery, a different product is pumped through the 

discharge hose to avoid contamination, a record including the date, time, original product, new 

product, and gallons pumped shall be maintained. These records shall be kept for a period of 12 

months and available for inspection by the weights and measures authority.

(Added 2018)

NIST OWM Detailed Technical Analysis: 

Mrs. Tina Butcher (NIST OWM), Mr. Jim Willis (New York), and Mr. Jim Hathaway (Murray Equipment) 

met on December 2, 2021 to discuss the proposed changes to VTM-18.1. There were specific concerns 

raised with VTM-20.1, which was previously included with this proposal that still needed to be addressed 

which included concerns with contamination, safety, and fraud. It was agreed that in order to further 

develop a joint proposal, there was a need to resolve the concerns addressed in VTM-20.1 to the extent 

possible. Mrs. Tina Butcher (NIST OWM), Ms. Diane Lee (NIST OWM), Mr. Jim Willis (New York), and 

Mr. John Hathaway (Murray Equipment) met again on January 3, 2021. As a result of this meeting all 

parties agreed with the existing item under consideration. In addition, the meeting participants agreed with 

adding a new User Requirement under UR.2.6. Clearing the Discharge Hose to the item under consideration 

to address the concerns with the use of manifold flush systems with dissimilar fluids a follows:

UR.2.6.2. Minimizing Cross Contamination. – When dissimilar products are dispensed through 

a single meter, the user shall take steps to ensure the system is properly flushed to minimize the 

potential for cross contamination of product in receiving tanks on subsequent 

deliveries. Dispensing products having radically different characteristics (e.g., gasoline and diesel 

fuel) through a single meter delivery system is not recommended.
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UR.2.6.3. Records. – Whenever, prior to delivery, a different product is pumped through the discharge 

hose to avoid contamination, a record including the date, time, original product, new product, and gallons 

pumped shall be maintained. These records shall be kept for a period of 12 months and available for 

inspection by the weights and measures authority.

(Added 2018)

Discuss points during the December 2, 2021 and January 4, 2022 meetings are outlined below: 

• Contamination and Safety.

o There is no disagreement over concerns about contamination and safety that can come about 

from inadvertent mixing of products in a storage tank.

o These concerns, however, are not unique to the use of manifold flush systems.

 Whether product is flushed using a manifold flush system or by flushing into a 

compartment from the top opening, the risk of contamination is present and is of 

concern.

o If flushing is to be prohibited and/or the use of single meter/multiple product applications, it 

should be universally applied and presented as a separate proposed change to NIST Handbook 

44, not just to systems equipped with manifold flush systems.

o Establishing minimum flush requirements might also assist with minimizing contamination.

o See recommendations below under “Dissimilar Fluids” and “Minimum Measured Quantity” 

that might help address these two concerns.

o It might also be acknowledged that the use of manifold flush systems is intended to address a 

different aspect of safety and that is safety of the driver when conducting a flush operation; the 

manifold flush system provides a safer way of accomplishing the task than climbing onto the 

top of a vehicle tank.

Dissimilar Fluids:

• The original proposal in 20.1 (from Murray Equipment) expresses concerns about the use 

of a single meter to deliver multiple products and suggests language that would limit the 

use of manifold flush systems only to those systems which have individual meters 

dedicated to individual products.

• Such concerns would appear to apply to all systems, not just those equipped with manifold 

flush systems.

• If a prohibition is to be added to NIST Handbook 44 regarding the use of individual meters 

for multiple products, this should be done as a separate requirement not included as part of 

paragraph S.3.1.

Minimum Measured Quantity (MMQ):
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• The concept of establishing a minimum delivery size would seem to help minimize 

concerns over possible contamination however it may be problematic to craft a requirement 

to adequately cover all applications.

Fraud.

• The concerns about potential fraud are quite valid and have been expressed in OWM’s 

comments from the inception of these requirements.

• The provisions for manifold flush were modified to include various provisions to limit that 

potential.

• Proposed changes to the existing language in the original Item 18.1 and as shown in the 

current “Item under Consideration” include additional recommendations to minimize the 

potential for fraud when installing and using manifold flush systems. If the additional 

provisions are adopted, this would help reduce that potential.

Additional Points – Mechanical Metering Systems:

• Some manufacturers raised questions regarding whether communication between the manifold flush 

system and mechanical metering systems is feasible, raising concerns about the newly proposed 

changes to S.3.1.1. Means for Clearing the Discharge Hose paragraphs (f) and (g).

• Those manufacturers expressed intent to explore this point more carefully.

NIST OWM provided previous comments to this item. Some oppose modifications that will restrict the 

use of manifold flush systems with only certain products. Some oppose use of manifold flush systems 

unless there is a restriction placed on the products with which the system can be used. The submitters 

(including NIST OWM) will need to work together to find a solution amenable to both views.

• As noted by Mr. Jim Willis (New York) during the NEWMA meeting, New York, Murray Control 

Systems, and NIST OWM will work together to finalize a recommendation for this item.

• NIST OWM looks forward to working with the other submitters (New York and Murray Equipment)

to find a solution that is more widely supported.

• For reference, OWM has retained the technical comments offered in its original analysis below.

Background to Consider:

o Based on comments at the 2019 NCWM Annual Meeting from the submitters of Item VTM-18.1 

(New York & NIST OWM) and with support from the Meter Manufacturers Association, the 

Committee agreed to modify items (f) and (g) in the proposal and to designate part (g) as 

nonretroactive as of January 2022 to become retroactive January 2025.

o At the July 2019 meeting, comments from Murray Equipment noted significant problems with 

fraud in Europe where they are permitted, suggesting the item be withdrawn.
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o Comments from FL at the July 2019 meeting suggested limiting the application to only certain 

products. This issue is addressed in the new Item 20.1 from Murray Equipment, which was 

subsequently withdrawn and is now included in this item (VTM-18.1).

o When presented for a vote, the revised item failed to obtain sufficient votes to “pass” or “fail” 

and was returned to Committee.

o In reviewing the proposals, one needs to recall that a manifold flush system allows liquid to be 

diverted from the discharge line on single hose multi-product VTMs so that liquid of one 

product is not mixed with liquid of another in the discharge line.

o OWM acknowledges the safety advantages of such a system since the operator does not have 

to climb on top of the VTM truck to flush product from the line before delivering another 

product.

o However, without appropriate safeguards, these systems represent a significant potential for 

fraud. Concerns have been voiced over this potential at multiple national and regional 

meetings.

• OWM offered the following comments on Item 18.1:

o At its Fall 2019 meeting, NEWMA recommended changes to extend the nonretroactive date. 

OWM recognizes this extension may help move the item forward and, thus, help reduce the 

potential for fraud when using these systems. OWM would also like to hear from the Meter 

Manufacturers Association regarding the difficulty designing communications between the 

metering system and the flushing system and the feasibility of an earlier nonretroactive date.

o At its Fall 2019 meeting, NEWMA also recommended eliminating the retroactive date. Given the 

potential to facilitate fraud and a number of comments received to that effect over the past several 

years, OWM is concerned with the proposed elimination of the retroactive date. However, if this 

will allow the item to progress it may represent a viable solution. OWM heard from NY regarding 

the extensive number of systems already in the field, particularly mechanical ones which may not 

lend themselves to modification. OWM is also interested in how others view the proposal to 

eliminate the retroactive date.

o The remaining regional associations recommended the item be given Developing status to permit 

the submitters to address concerns raised during the Annual Meeting.

o Comments from the SWMA voice serious concern about the potential for cross contamination of 

products. The proposal in Item 20.1 may help to address this by including limitations on the type 

of products with which these systems can be used.

o OWM believes the term “operational” should be deleted from proposed paragraph UR.2.6.1. since 

the key point is that the system should not be used when a commercial transaction is in progress.

• OWM offered the following comments to consider in addressing the recommendations originally 

presented in VTM-20.1 and now included as part of this item (VTM-18.1):
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o OWM notes that one jurisdiction (NY) in NEWMA specifically opposes the limitation of product 

types. The S&T Committee will have to consider how to address this.

o After discussing the proposed limitation of using manifold flush systems to only products other 

than engine fuels with NY W&M, OWM recognizes there may be instances where a VTM is used 

to transport only engine fuels of different types and grades. OWM recognizes that a blanket 

limitation may unintentionally impact applications that may not have been considered under Item 

20.1.

o While OWM continues to have concerns regarding the safety of delivering products such as 

gasoline and home heating oil through the same meter (and questions whether a single meter is 

suitable for such purposes), OWM recognizes this is already a widespread practice in the industry 

and placing a blanket limitation may not best serve the community. OWM suggests working with 

the submitter of 20.1 to see if there are ways to resolve specific concerns without impacting other 

applications.

o In its review of these issues, OWM also noted the need to clarify when paragraph S.3.1.1. applies 

and suggests the addition of the terms “multiple-product, single discharge hose” to both the title 

and preamble.

Summary of Discussions and Actions:

Manifold flush systems are typically used on VTM’s with multiple compartments, delivering multiple 

products through a single hose. The purpose of the system is to allow the driver a means of clearing the 

hose of product prior to delivery (e.g., clearing the hose of diesel fuel before delivering clear kerosene). 

These types of systems are often marketed as a safety feature in that it eliminates the need for the driver to 

climb on top of the truck to clear the hose. Such systems are also useful in helping avoid crosscontamination. Typically, the driver attaches the nozzle to the manifold and pumps product back into the 

supply tank via the manifold until the previous product is flushed from the hose. There is often a sight 

gauge which allows the driver to tell when the product is flushed.

The obvious concern is that this makes it very easy for the driver to circulate product through the meter 

prior to delivery, which goes against S.3.1. It should be noted that it also goes against S.3.1. when the 

driver climbs on top of the tanker and clears the hose. The submitter has voiced concerns involving the 

safety of this practice noting that the operator could be subject to falls from the tanker. The distance 

between the flush system and the hose reel is also a factor in how easy it is for the driver to facilitate fraud.

Manifold flush systems are available from OEMs and can be found in various catalogs. Looking on multiple 

websites, these systems are being installed across the country and for some manufacturers seem to be 

standard equipment for new trucks. The submitter of VTM-1 has also seen these systems installed on trucks 

that are for sale where the seller notes the system as a selling point. He can foresee these systems being 

mandated in the future as a safety requirement and would like W&Ms to have a clear policy before that 

happens.

Another concern is with systems fabricated onsite. These systems are often difficult to distinguish and 

installed in an inconspicuous manner. While the submitter of VTM-1 has ordered many of these systems 

out-of-service until repaired, it can be frustrating for the owner because the truck was used in another state 

for years and approved by weights and measures jurisdiction in the other state. This lack of uniformity is 

problematic for both officials and private industry.
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This item was originally submitted by New York Department of Agriculture as a Developing item. The 

item was intended to encourage uniformity in how manifold flush systems were being designed, installed, 

and regulated with the goal of minimizing the facilitation of fraud through the use of these systems while 

realizing the safety benefits provided by such systems.

This item was one of two separate parts of VTM-1 (previously VTM-1A and VTM-1B) considered by the 

Committee at the 2018 NCWM Annual Meeting. The item voted on at the 2018 Annual Meeting, VTM1A was adopted and VTM-1B was assigned an Informational status and carried-over to the next cycle.

In the period between 2018 and 2021, the Item under Consideration underwent multiple changes based on 

feedback received at regional and national meetings and, more recently based on collaborations amongst 

the submitter of this and other related items, which resulted in the current Item under Consideration. In 

developing the current proposal, the submitters considered concerns raised regarding the use of these 

systems, including the potential for facilitation of fraud with the use of these systems; the potential for cross 

contamination of products in different tank compartments; and the suitability of using a single meter for 

multiple product types. These concerns were balanced against comments indicating that product handling 

practices have occurred for many years without the use of such systems and there are distinct safety 

advantage for drivers when these manifold flush systems are used.

At the 2022 NCWM Interim Meeting, the Committee heard from Mr. Jim Willis (New York, submitter) 

and provided an update that contained amended language with modifications to UR.2.6.2 and creating 

UR.2.6.3. The amendments were agreed upon by the other joint submitters, NIST OWM, and Murray 

Equipment. Mr. Willis stated that the new proposed language would hold device owners responsible for 

ensuring there is no cross-contamination of fuels and also allows jurisdictions to prohibit using manifold 

flush systems or dispensing dissimilar products through a single meter. The Meter Manufacturers 

Association, Mr. John Hathaway (Murray Equipment), Ms. Cheryl Ayer (New Hampshire), and Mr. John 

McGuire (New Jersey) also voiced support for the amended language and urged the item be given a voting 

status. Mr. Hal Prince (Florida) opposed the entire item, indicating the use of a single meter to dispense 

different products is not legal in his state and has concerns of cross-contamination of fuel. During the 

Committee work session, the Committee assigned this item a Voting status with the amended language seen 

above as the Item under Consideration. The item as presented to the 2022 NCWM Interim Meeting can be 

seen below the Item under Consideration.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Matt Douglas (California - DMS): California supports further development. Has there been any further 

development since the annual meeting?

The WWMA S&T Committee recommends the status remain Developmental. The Committee recommends 

that the submitters (NIST, New York, and Murray Equipment) continue their work together to further 

develop the item. 

Southern Weights and Measures Association
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During the 2021 Annual Meeting Open Hearing no comments were received on this item. NIST requests 

this item remain Developmental. 

This Committee recommends the status remain Developing at the request of the submitter. 

Northeastern Weights and Measures Association

During the 2021 NEWMA Interim Meeting open hearings, comments were heard from Mr. Jim Willis (New 

York) as submitter of this item. He stated that communication was in process with Murray Controls in 

regard to changes to this proposal. The flushing “systems” have been around for decades and not just as 

OEM systems. The driver would climb on top the truck to flush a line. Now they can flush the hose without 

the danger of falling off the truck. Some suggestions have been made to limit the products carried on the 

truck to similar products. NYS does not support such language as the flush system actually allows for the 

safe clearing of the hose and minimizes contamination. A flush manifold enables a truck to carry different 

products at the same time.

 

Mr. Jim Willis (New York) recommended further development.

Mr. Lou Sakin (Hopkinton/Northbridge, Massachusetts) asked when development may be finished. Mr.

Willis responded that hopefully by the NCWM Interim Meeting.

Mr. John McGuire (New Jersey) supported developing status.

The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status and encouraged New York, NIST, and Murray Controls to continue working towards full 

development. 

During the 2022 NEWMA Annual Meeting, NEWMA heard comments from Mr. Jim Willis (New York), 

Mr. John McGuire (New Jersey), Mr. Ethan Bogren (Westchester County, New York) and Mrs. Tina 

Butcher (NIST OWM) who rose in support of the item as Voting.

After hearing comments from the floor, the Committee considered the item to be fully developed and 

recommended the item retain a Voting status.

Central Weights and Measures Association 

During the CWMA 2021 Interim Meeting, the CWMA heard comments from the floor. Ms. Diane Lee

(NIST OWM) commented about this item in the NCWM Annual report. Mr. Charles Stutesman (Kansas)

asked if the intent of this item was for vehicle motor fuel or for all items such as home heating oil.

CWMA S&T Committee recommends item as a Developing item.

During the 2022 CWMA Annual Meeting, the CWMA heard no comments from the floor and 

recommended this item remain a Voting item.
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VTM-20.2 A Table T.2. Tolerances for Vehicle Mounted Milk Meters.

(NOTE: This item was revised based on changes that were made by the Committee at the 2021 Interim 

Meeting.) 

(NOTE: The Item under Consideration was removed from the voting consent calendar at the 2021 Annual 

Meeting and the S&T Committee made this a Developing item.) 

Source: POUL TARP A/S

Purpose and Justification:

Change tolerances to accommodate more efficient milk-metering systems.

OWM Executive Summary for VTM-20.2 – Table T.2. Tolerances for Vehicle Mounted 

Milk Meters.

OWM Recommendation OWM supports the Assigned status for this item and encourages the task 

group to continue its review of the proposed OIML tolerances for Vehicle Tank Milk Meters.

• One of the questions raised concerning the current proposal that includes the OIML tolerances is that 

the proposal includes tolerances for the system and a separate tolerance for the meter. 

• NIST OWM observed that a separate tolerance for the meter would apply during OIML type 

evaluation. However, NIST HB 44 only includes requirements for the entire measurement system 

and not separate main elements nor does it have separate tolerances for main elements known to be 

metrologically significant. 

• NIST OWM will look forward to more discussion of this item during task group meetings.

Table 3. Summary of Recommendations

VTM-20.2 Table T.2. Tolerances for Vehicle Mounted Milk Meters.

V D W A I Notes* Comments

Submitter/Task 

Group 

Task Group Documents:

• Milk Meter Tolerance Spreadsheet (01-14-

2021)

• Milk Meter Tolerance Report (Task 

Group, 07-19-21)

• Proposed Tolerance Tables (01-10-2022)

• Milk Meter NTEP CC Data (01-10-2022)

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 
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Table 3. Summary of Recommendations

VTM-20.2 Table T.2. Tolerances for Vehicle Mounted Milk Meters.

V D W A I Notes* Comments

Letters of Support Letters of Opposition Notes

Industry

Agri-Mark (01-13-20)

Dean Foods (01-14-20)

Dairy Farmers of America 

(01-14-20)

Danone North America 

(01-15-20)

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Vehicle-Tank Meters Code as follows: 

T.2. Tolerance Values. – Tolerances shall be as shown in Table 1. Accuracy Classes and Tolerances for 

Vehicle-Tank Meters Other Than Vehicle-Mounted Milk Meters and Table 2. Tolerances for VehicleMounted Milk Meters.

(Amended 1995, 20XX) 

Table 2. 

Tolerances for Vehicle-Mounted Milk Meters

Indication

(gallons)

Maintenance Tolerance

(gallons)

Acceptance Tolerance

(gallons)

100 0.5 0.3

200 0.7 0.4

300 0.9 0.5

400 1.1 0.6

500 1.3 0.7

Over 500 Add 0.002 gallon per indicated 

gallon over 500

Add 0.001 gallon per indicated 

gallon over 500

 (Added 1989)
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Table 2. 

Tolerances for Vehicle-Mounted Milk Meters

Acceptance Tolerance Maintenance Tolerance

Complete Measuring 

System 0.5 % 0.5 % 

Meter Only 0.3 % 0.3 %

(Amended 20XX) 

NIST OWM Detailed Technical Analysis:

A Milk Meter Task Group Meeting last met on January 3, 2022 to further discussed the proposed tolerances 

for Milk Meters. This is a proposal to increase the tolerances for vehicle mounted pump metering systems 

that measure milk and the proposed tolerance are those used in OIML for milk measuring systems.

Proposed 

Tolerance

Current NIST 

Tolerance

Proposed 

Tolerance

Current NIST 

Tolerance

Collected volume Maintenance Maintenance Acceptance Acceptance

Gallon Percent % Gallon Percent % Gallon Percent % Gallon Percent %

50 Gallon 0.25 0.5 % 0.25 0.5 %

100 Gallon 0.5 0.5 % 0.5 0.50 % 0.5 0.5 % 0.3 0.30 %

200 Gallon 1 0.5 % 0.7 0.35 % 1 0.5 % 0.4 0.20 %

300 Gallon 1.5 0.5 % 0.9 0.30 % 1.5 0.5 % 0.5 0.17 %

400 Gallon 2 0.5 % 1.1 0.275 % 2 0.5 % 0.6 0.15 %

500 Gallon 2.5 0.5 % 1.3 0.26 % 2.5 0.5 % 0.7 0.14 %

The submitter (Poul Tarp) explained that use of vehicle mounted pump metering systems to measure milk 

reduces the amount of time needed to collect and process the milk which reduces the cost and loss of product 

that would occur with a slower measurement process. But, with the use of vehicle mounted pump measuring 

systems, entrained air is produced that cannot be removed and this air is measured as product. As such, with 

the use of a pump metering system there is an inherit loss to the buyer. Although the system has means for 

air elimination, not all entrained air can be removed and this is the submitter’s reason for requesting that the 

tolerances currently in the HB be increased. 

Poul Tarp also noted that it is recognized by the European Standardization Agencies: Measuring Instrument 

Directive (MID) and Organization of Legal Metrology (OIML) Recommendation (R) 117 Dynamic 

measuring systems for liquids other than water and the dairy industry in general that it is not possible to 

remove all the air from milk before measuring it. Poul Tarp notes that the MID and OIML (R) 117 standards 
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specify that measurements of a vehicle mounted milk metering system must not result in inaccuracy of more

than 0.5 % at any given amount being collected from a minimum of 50 gallons and up to +500 gallons. NIST 

HB 44 Section 3.31.has a designated tolerance table in volume for vehicle-mounted milk meters that was 

added to the code in 1989 with an acceptance tolerance of 0.3 and maintenance tolerance of 0.5 gallons for 

the first 100 gals and these tolerances decrease in percent tolerance as the indicated volume increases, as was 

reported in a presentation from Poul Tarp: 

NIST OWM’s initial points to consider as the Committee began to deliberate on the proposal were:

- Are there other methods that can be employed to remove entrained air from the milk?

- Can the amount of error introduced from entrained air be determined? 

- Should NIST HB 44 tolerances be aligned with OIML R 117 less stringent tolerances, as 

recommended by the submitter.

- Should there be a separate tolerance table to address vehicle mounted pump metering systems?

During the 2019 Interim Meeting another company stated that they met the current tolerances in HB 44 and 

were issued an NTEP certificate and believe that the current tolerances are appropriate. Other State 

regulators commented that the current certificate was limited to testing up to 300 gallons. At that time the 

S&T Committee assigned a task group to this item and NIST OWM expressed interest in working with the 

task group. 

Mr. Charlie Stutesman, Kansas, and Chair of the Task Group sent an email to the Milk Meter Tolerance 

Task Group (TG) providing a list of the TG members and the TG’s mission. Mr. Stutesman also informed 

the Task Group that most communication will be conducted via e-mail and that face-to-face meetings will 

be planned at Interim and Annual Meetings.

The following list contains the names of members on the Milk Meter Tolerance TG:

Chair – Mr. Charlie Stutesman (Kansas)

NEWMA Representative – Mr. Jim Willis (New York)

SWMA Representative – TBD

WWMA Representative – Mr. Jeff Cambies (California)

NTEP Technical Advisor – Mr. Mike Manheim

NIST Technical Advisor – Ms. Diane Lee

Measurement Canada Technical Advisor – Mr. Luciano Burtini 

Industry Representative – Mr. Carey McMahon (Poul Tarp)

Industry Representative – Ms. Leigh Hamilton (Piper Systems)

Industry Representative – Mr. Brandon Meiwes (Dairy Farmers of America)

Industry Representative – Mr. Bob Fradette (Agri-Mark)

Mr. Mitch Marsalis (Los Angeles County, California) has agreed to be the SWMA representative. I am 

just waiting on formal assignment by the NCWM Chair for Mitch.

Milk Meter TG Mission:

The mission of the Task Group is to review and possibly recommend changes to the tolerances that apply 

to milk meters, which may include milk measuring systems, in Sections 3.31. Vehicle Tank Meters, Section 

3.35. Milk Meters, Section 3.37. Mass Flow Meters, and Section 4.42. Farm Milk Tanks. This TG will 
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consider the tolerances proposed in S & T item VTM-20.2 and the tolerances in OIML R 117-2 “Dynamic 

measuring systems for liquids other than water” in their discussion.” 

Mr. Stutesman provided the Task Group with milk meter tolerances and requirements from OIML-R117-

2: 2007, NIST HB 44 Tolerances for Milk Meters that are located in the VTM Code Section 3.31, the Mass 

Flow Meter Code Section 3.37, and the Farm Milk Code Section 4.42 and Measurement Canada’s 

tolerances for milk meters and requested feedback from the task group on appropriate tolerances to apply. 

A Task Group member from Poul Tarp, the original submitter of the item, recommended that the proposal 

be changed to align NIST HB 44 with the tolerances for milk meters in OIML R-117-2. Mr. Stutesman 

circulated a proposal for consideration by the task group that would aligns the tolerances in NIST HB 44 

Section 3.31 Table 2 with OIML to tolerances. OIML Tolerances seem to apply two different tolerances. 

0.5 % tolerance for milk meters in a system and 0.3 % tolerance for a meter outside of a system that is used 

to measure milk. The proposed tolerances and changes to NIST HB 44 are provided below:

Table 2. Tolerances for VehicleMounted Milk Meters

Indication 

(gallons)

Maintenance

Tolerance

(gallons)

Acceptance 

Tolerance 

(gallons)

100 0.5 0.3

200 0.7 0.4

300 0.9 0.5

400 1.1 0.6

500 1.3 0.7

Over 500 Add 0.002 gallon per 

indicated gallon 

over 500

Add 0.001 gallon per indicated 

gallon over 500

Table 2. Tolerances for Vehicle- Mounted Milk Meters

Indication 

(gallons)

Acceptance 

Tolerance

Maintenance 

Tolerance

Complete Measuring 

System

0.5 % 0.5 %

Meter Only 0.3 % 0.3 %

Proposed change to Handbook 44- Simple rewrite of table 2 and paragraph T.4. in 3.31 VTM Code and 

Table 1 in 3.35 Milk Meter Code.

3.31 Vehicle Tank Meters
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T.2. Tolerance Values. – Tolerances shall be as shown in Table 1. Accuracy Classes and Tolerances for 

Vehicle-Tank Meters Other Than Vehicle-Mounted Milk Meters and Table 2. Tolerances for VehicleMounted Milk Meters.

(Amended 1995, 20XX)

If changes to the product depletion test tolerances in Handbook 44 are made to match OIML R117-1 

paragraph 2.10.1:

T.4. Product Depletion Test. – The difference between the test result for any normal test and the 

product depletion test shall not exceed 0.5 % of the volume delivered in one minute at the maximum 

flow rate marked on the meter for meters rated higher than 380 Lpm (100 gpm) or 0.6 % of the volume 

delivered in one minute at the maximum flow rate marked on the meter for meters rated 380 Lpm (100 

gpm) or lower. Test drafts shall be of the same size and run at approximately the same flow rate. For 

vehicle tank meter measuring systems used to measure milk, the effect due to the influence of the 

air or gases on the measuring result shall not exceed 1.0 % of the quantity measured.

Mr. Charlie Stutesman also asked the Task Group if consideration should be given to updating all of the 

codes pertaining to milk metering devices in NIST HB 44 and if all milk metering requirements should be 

included in a single code. 

The NCWM Milk Meter Tolerance Task Group met virtually on January 7, 2020. During this meeting the 

Task Group discussed:

- the system of milk collection from farm to processer (seller to buyer), 

- the operation of metering systems that measure milk to include discussion of air elimination 

systems,

- review of the milk measuring tolerances in NIST HB 44 from 1919 to 2020,

- review of the proposal to harmonize the NIST HB 44 VTM code milk metering tolerances with 

OIML tolerances for single milk meters and milk meter measuring systems, and

- whether or not the task group wanted to consider expanding its scope to include combining all milk 

metering requirements in NIST HB 44 to a single code. 

By consensus the Task Group agreed with harmonizing the VTM milk metering tolerance with OIML R 

117 tolerances and that those tolerance be presented during the NCWM 2021 Interim Meeting for 

discussion. The Task Group also agreed that a request should be made to the S&T Committee to expand 

the scope of the Task Group to include combining milk meter requirements in NIST HB 44 to a single code.

Mr. Charlie Stutesman, Task Group Chair, proposed the Task Group visit a location to review Milk 

Measuring systems in use as its next step. The Task Group last met on July 1, 2021. 

NIST OWM is looking forward to gaining additional information on the various systems for milk metering 

and their capabilities and believes the task groups plans to visit a site will be helpful in determining the best 

approach for acceptable solution for milk metering systems. In the meantime, harmonizing with OIML 

tolerances may be an acceptable path forward. OWM reiterates its original questions concerning the 

operation of milk metering systems. OWM encourages the task group to continue its investigation of these 

systems.
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Summary of Discussions and Actions:

A Milk Meter Tolerance Task Group was formed and assigned to this item. Please contact the Task Group 

chair for more information:

Mr. Charlie Stutesman

Kansas Department of Agriculture

(785) 564-6681, charles.stutesman@ks.gov

Existing tolerances are based on the accuracy of the Flow meter itself. The proposed Tolerances are based 

on Milk Metering Systems where the magnetic flow meter is a part of the Milk Metering system handling 

milk containing air.

The accuracy of the Flow meter will always be influenced by the way it is used. The only way you can 

obtain the accuracy described by the manufacture is when the flow meter is operating as a “stand alone” 

unit and, equally important, only if the product passing through the flow meter is complete air-free.

The submitter provided the following:

During the past 20 years, the need for improved efficiency in the collection of milk has resulted in the 

use of milk pumping equipment being installed on milk tankers. 

One of the most obvious places for a modern Dairy to optimize is the amount of time that the milk 

tanker uses to make a collection. If you can reduce the collection time at each farmer, the Dairy will be 

able to get a significant reduction in collection and transport cost for the benefit of the Farmer, 

Consumer and the Dairy itself. At the same time, you will get an environmental benefit as a result of 

reduced CO2 in the milk collection process. 

The consequence of introducing pump systems on milk tankers is that it causes air to be mixed with the 

milk which again will influence the accuracy of the magnetic flow-meter mounted in the system. Milk 

entrains air unlike petroleum liquids which do not. As you know, the flow meter will count anything 

that passes through the meter – liquid as well as air – and it is therefore essential that as much air as 

possible is removed from the milk before it reaches the flow-meter. However, it is widely recognized 

that it is not possible to remove all the air from the milk, which will result in an inaccuracy. 

It is therefore essential that the tolerances for vehicle mounted milk pump systems using magnetic flowmeters for determining milk volume reflects todays way of collecting milk. This means that existing 

Tolerance for milk meters cannot be used when the milk meter is a part of a system where different 

system parts will influence the accuracy of the count. Such milk metering systems will need to be 

classified with their own tolerances.

Based on our 25 years of experience as a manufacturer of these systems and more than 3000 

installations on milk trucks operating in more than 15 countries, we would like to propose that the 

Tolerance for Vehicle Mounted Milk Metering Systems is changed from 0.3 % to 0.5 % and that the 

tolerances will be listed and classified separately and not be associated with products from the oil 

industry. Our proposal is consistent with Weights & Measures tolerances accepted around the world.

We hope that the NCWM will consider our proposal and we will be more than happy to meet with you 

and answer any questions you may have. We believe that a change of Tolerance is necessary in order 

for the Handbook 44 to reflect today ́s milk collection and the technical progress within milk collection.
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Yours sincerely

Poul Tarp

President POUL TARP A/S 

The POUL TARP milk pump system holds an MID approval which is recognized and in accordance with 

guidelines and standards described in the OIML - INTERNATIONAL ORGANIZATION OF LEGAL 

METROLOGY

FLOW COMPUTERS REGULATION IN THE US:
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The standards related to metrological aspects come from OIML R117-1 for liquids (Dynamic measuring 

systems for liquids other than water, part 1: Metrological and technical requirements) and documents D11 

(General requirements for electronic measuring instruments) and D31 (General requirements for softwarecontrolled measuring instruments) from OIML.

At the NCWM 2020 Interim Meeting Mr. Carey McMahon (Poul Tarp) provided a presentation on his 

company’s VTM milk metering system advocating for expanding tolerances for these systems.

Ms. Leigh Hamilton (Piper) provided a presentation concerning the piper system and stated in her 

presentation that piper currently has an approved NTEP certificate for their device that is in service in the 

U.S. Ms. Leigh opposes this item to increase the tolerances for milk meters and noted in her presentation 

that there may not be a need to increase the tolerances in order to move forward in allowing innovation in 

milk measurements. 

Mr. Charles Stutesman (Kansas) provided a presentation on research that KDA has done on the history of 

3 HB 44 Codes (3.31. VTMs, 3.35. Milk Meters, and 4.42. Farm Milk Tanks) and the issue of Piper’s NTEP 

Certificate. Mr. Stutesman discussed complications involved in measurement of product using various 

methods and potential shortcomings of Piper’s NTEP Certificate.

Mr. Doug Musick (Kansas) stated that he does not believe there is enough information presented to change 

existing tolerances and noted that the Piper system was only evaluated for accuracy up to a measurement 

of 300 gallons. He also noted that he believes that Piper’s certificate should be amended to qualify the 

system for draft sizes up to 300 gallons. Mr. Mike Keilty (Endress + Hauser) commented that he had 
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concerns with Piper’s certificate. Ms. Hamilton noted that Piper followed and followed guidelines as 

provided during the NTEP evaluation. Ms. Diane Lee (NIST OWM) stated that the Committee may want 

to consider a developing status for this item and that more information is needed concerning air elimination 

methods for milk metering systems.

A representative from the Dairy Farmers of America, stated that they oppose the increase in tolerance but 

supports the use of VTM metering systems. Mr. Carey McMahon (Poul Tarp) pointed out that the Poul 

Tarp system can be accurate for any size measurement, but the beginning and end of the measurement 

would not be accurate measures (within tolerance) due to entrained air in the product when the flow is not 

uniform. Mr. Dmitri Karimov (MMA) stated that the proposal should be further developed and pointed out 

that due to the tolerance structure becoming more stringent as the volume of the measurement increases, 

the acceptance tolerance at 500 gallons is unreasonable. Mr. Hal Prince (Florida) stated that he does not 

agree with expanding the tolerances. Mr. Prince believes that air elimination should be the focus and that 

the proposal should be assigned to a task group. Mrs. Tina Butcher (NIST OWM) noted that testing should 

be performed using multiple quantities and flowrates. Mr. Charles Stutesman (Kansas) pointed out that 

confusion is generated by multiple HB 44 codes addressing the measurement of milk and that the proposal 

should be assigned to a TG to sort this out. Mr. Stutesman also pointed out there is no requirements in HB 

44 for air elimination pertaining to milk metering in these codes. Mrs. Butcher noted that the current HB 

44 requirements may not be flexible enough for this new technology and that the existing codes may need 

to be reviewed and updated.

Ms. Leigh Hamilton (Piper) stated that this is not simply a consideration of only a change in tolerances. 

There are other requirements (currently in the OIML standard) that should also be considered in making 

any changes to the existing HB 44 requirements. Mr. Mike Keilty (Endress+Hauser) stated that air 

elimination is a difficult problem to mitigate and noted that he is not sure if it is necessary to expand the 

existing tolerances or make other amendments. Mr. Carey McMahon (Poul Tarp) stated that using the 

existing HB 44 tolerances in the VTM Code, at a draft of 5000 gallons, the tolerance value is highly 

unreasonable Charles Stutesman (Kansas) noted that the type evaluation performed on the Piper system 

was limited to a draft of 300 gallons. If evaluation had included other draft sizes, the Piper system mat 

have failed the testing.

Mr. Ken Ramsburg (Maryland) stated that the proposal should be given a developing status. Mr. Ramsburg

agreed that there is no existing requirement for this type of system addressing air elimination and stated 

that the flow meter, air eliminator, plumbing, and pumps all need to be considered during evaluation and 

the evaluation should be conducted on the system. 

Mr. Tim Chesser (Arkansas) questioned whether the flow meter used in the system is appropriate and noted 

that there are many unanswered questions surrounding this issue. Mr. Jim Willis (New York) recommended 

a developing status for this item. Mr. Kevin Schnepp (California) stated that although he is opposed to 

relaxing existing tolerances, he supports the development of this proposal by an assigned task group.

During the Committee’s work session, the Committee agreed that this item has merit and should be given 

an Assigned status. The charge to the assigned task group will be to address three HB 44 codes (VTM, 

Farm Milk Tanks and Milk meters) to review the requirements and tolerances found in these codes and 

assess the need for changes.

The NCWM 2020 Annual Meeting, due to the 2020 COVID-19 pandemic, this meeting was adjourned to 

January 2021, at which time it was held as a virtual meeting. Due to constraint of time, only those items 

designated as 2020 Voting Items were addressed. All other items were addressed in the subsequent 2021 

NCWM Interim Meeting.
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At the NCWM 2021 Interim Meeting, the Committee heard from Mr. Charles Stutesman (Kansas, Chair of 

the Milk Meter Task Group) who gave an update on the task group activities. Mr. Stutesman reported that 

the Milk Meter Task Group worked via e-mail communication and reviewed and discussed the proposed 

Milk Meter Tolerances in Agenda item VTM-20.2. The Milk Meter Task Group also discussed the 

tolerances that are included in NIST HB 44 for Milk meters in various parts of HB 44 which include the 

VTM, Section 3.31, Farm Milk Tanks, Section 4.42., Mass Flow Meters, Section 3.37, and Milk Meters, 

Section 3.35. Mr. Stutesman also reported that the Task Group reviewed OIML tolerances for milk meters. 

Mr. Stutesman stated that after a review of the various tolerances, the Task Group agreed that the OIML 

tolerances provide tolerances that encompassed the system of measuring milk and not just a tolerance for 

the performance of the meter. The Milk Meter Task group agreed with proposing the use of the OIML milk 

meter tolerance as the milk meter tolerances in the VTM code. Mr. Stutesman provided a copy of the 

proposed changes to VTM-20.2. The proposed tolerances will align the tolerances in the VTM Code for 

Milk Meters with OIML Milk Meter Tolerances. Mr. Stutesman requested that this item move forward as 

a Voting item. The Committee also heard from Mr. Clark Cooney who noted that he supported the items 

as Developing because one company mentioned meeting the existing tolerances. It was mentioned that the 

company’s testing was only performed over a limited range of volumes.

During the Committee’s work session, the Committee agreed with the proposal from the Milk Meter Task 

Group to adopt OIML tolerances for milk meters in the VTM code, that this item be given a Voting status, 

and that the Item under Consideration be replaced with the work group’s proposal to adopt OIML 

tolerances. The Committee also agreed with expanding the Task Group to address other milk meter codes 

in HB 44. The Item under Consideration above are the tolerances agreed to by the Milk Meter Task Group 

and that align with OIML tolerances. 

At the NCWM 2021 Annual Meeting Mr. Stutesman provided an update on the Milk Meter Task Group 

activities. Mr. Stutesman noted that there was a field trip to observe milk metering systems. He noted that 

the proposed tolerances will align the milk tolerances with the OIML tolerances for milk meters and Mr. 

Stutesman noted that the OIML tolerances provides one tolerance for the meter and another tolerance for a 

milk metering system. He also noted that it may be impractical to perform an air eliminator test on these 

devices due to comingling of product. 

During the Committee’s work session, the Committee agreed to a Voting Status for this item and added it 

to its voting consent calendar.

During the voting session, Mr. Stutesman asked that consideration be given to adding a non-retroactive date 

to the proposed tolerances. It was questioned during the discussion that if a non-retroactive date was added 

to the tolerances, then, what tolerances would apply to existing meters that had been manufactured and 

tested prior to the non-retroactive date. One of the concerns expressed with having a new tolerance table 

without a nonretroactive date was whether or not existing devices would be required to be reevaluated in 

the NTEP. The conference voted against adding the nonretroactive requirement to the proposed tolerance 

table and the Item under Consideration to change the tolerances failed to receive the 27 votes from the 

House of State Representatives, so the item failed and went back to the S&T Committee. The S&T 

Committee agreed to a Developing status for this item. 

Note: For reference, the Item under Consideration that was included in the 2021 NCWM Interim Meeting 

Agenda is provided below: 
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Table 2.

Tolerances for Vehicle-Mounted Milk Meters

Indication

(gallons)

Maintenance Tolerance

(gallons)

Acceptance Tolerance

(gallons)

100 0.5 0.6 0.3 0.5

200 0.7 1.2 0.4 1.0

300 0.9 1.8 0.5 1.5

400 1.1 2.4 0.6 2.0

500 1.3 3.0 0.7 2.5

At the NCWM 2022 Interim Meeting Mr. Charlie Stutesman (Kansas) spoke as Chair of the Milk Meter 

Task Group. He requested that this item be assigned back to the Task Group for further development. Mr. 

Stutesman provided an update on the Task Group meeting in January 2022 in which they discussed 

tolerances in both 3.31 Vehicle Tank Meters and 3.35 Milk Meters and the need to have the tolerance be 

applied to both vehicle mounted and station meters as the manufacturers are developing meters that will be 

capable of being installed in either application. The tolerance tables can be found in the supporting 

documents. Mr. Stutesman also renewed the Task Group’s request to expand its scope to include possibly 

creating a new code that contains requirements of both vehicle mounted and stationary milk meters and 

metering systems due to the unique properties of milk as a liquid. Speaking on behalf of himself, Mr. 

Stutesman (Kansas) stated that he has provided a document in the supporting documents that outlines the 

four active and five inactive NTEP certified meters and metering systems in terms of test draft size and 

applicable tolerances. He noted that the active four have a range of 0.12 %-0.6 %. He also noted that milk 

meters are the only liquid measuring device where the volume tolerance decreases as the draft size increases 

and suggests percentages more in line with OIML tolerance would be more appropriate. Mr. Ken Ramsburg 

(Maryland) suggested combining the two tolerances to be used for field evaluations. Ms. Diane Lee (NIST 

OWM) commented that the Task Group should work toward making all test methods uniform. Ms. Lee 

also suggested that the Task Group and Committee look at the comments from various companies 

concerning different tolerance along the distribution line for milk. Mr. Doug Musick (Kansas) and Mr. 

Matt Douglas (California) supported assigning this item to the Task Group for further development. During 

Committee work sessions, the Committee agreed to assign this item back to the Milk Meter Task Group so 

they may continue to ascertain data. In addition, the Committee agreed to request that NCWM Chairman 

Ivan Hankins expand the scope of the Task Group to include all reference to milk meters, meter systems 

and related test methods, specifications and tolerance in an effort to harmonize the codes. 

The Committee agreed to an Assigned status for the item.

Regional Association Reporting: 

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:
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Ms. Diane Lee (NIST OWM) put forth by Task Group working on milk meters. They’re still in process of 

reviewing. It was put forth to vote but last-minute change to make it non retroactive. This put it back to 

Developing. What would happen to devices that are currently in the field? During the Annual Meeting this 

was returned back to Developing and NIST supports Developing. 

The WWMA S&T Committee recommends the status remain Developmental. During the 2021 S&T Work 

Session Ms. Diane Lee (NIST OWM) was asked for further clarification on her testimony. She provided 

the following clarification: “During the Annual Meeting a proposal was made to add a non-retroactive date. 

Because questions were raised as to how this would affect existing devices the item was moved from Voting 

to Developing.” The Committee looks forward to hearing from the working group.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing no comments were received on this item. 

This Committee would like to see more evidence and reasoning on why these devices should not have to 

meet the existing tolerances, and why the tolerances listed are appropriate.

This Committee recommends the item remain Developing so that the submitters can gather more evidence 

about the accuracy of these devices. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Jim Willis (New York) commented as a member of the Task Group about the field trip that was taken 

in Rochester New York just prior to the NCWM meeting in July to witness the truck mounted Milk Meters 

in action. The Task Group is asking for recommendations in regards to a tolerance value that people would 

be comfortable with. Mr. Willis commented that the tolerance of 0.5 % is considered too large by some, 

but we have 0.4 % in the handbook now in-regards to checking a milk tank with a meter. 

Mr. Jimmy Cassidy (Massachusetts) asked if any systems currently meet the requirements in the handbook 

and Mr. Willis replied that currently there is one milk meter system on tank trucks that meets the 

requirements currently in the handbook. 

The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status.

During the 2022 Annual Meeting Open Hearing Mr. Jim Willis (New York) commented as a member of 

the Milk Meter Task Group. He indicated that the Task Group has made strides and hopes for ability to 

perform additional work on the item.

After hearing comments from the floor, the Committee recognized the need for further development of the 

item and recommended that the item retain an Assigned status. The Committee recommends the NCWM 

Milk Meter Task Group continue to work with stakeholders to further develop this item.
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Central Weights and Measures Association 

During the 2021 Interim Meeting Open Hearing, the Committee heard comments from the floor. Mr. 

Charles Stutesman (Kansas) would like to see item be returned to Task Group.

CWMA S&T Committee recommends that the item be assigned to Milk Meter Tolerance Task Group and 

be an Assigned item.

During the 2022 Annual Meeting Open Hearing Mr. Charles Stutesman (Kansas, Chair of Milk Meter 

Tolerance Task Group (MMTTG)) – following 2022 NCWM Interim Meeting, this item was sent back to 

the MMTTG. Moving forward with staying with original tolerances that were proposed. Request to expand 

scope has been submitted. There will be a MMTTG meeting prior to the July annual meeting. Hoping to 

move forward and elevate to Voting status for next cycle.

The CWMA S&T Committee recommends this item to remain an Assigned item. 

LIQUIFIED PETROLEUM GAS AND ANHYDROUS LIQUID-MEASURING DEVICES

LPG-15.1 D N.3. Test Drafts.

Previously LPG-4 

(Note: In 2019 this item was combined with Block 1 “Terminology For Testing Standards” and other items 

that addressed terminology for standards and the use of “master meters.” Based on comments heard during 

the 2021 Annual Meeting, the S&T Committee recommended that all items that were combined with Block 

1 “Terminology For Testing Standards” that originally appeared as a separate item or a separate block of 

items on the S&T agenda prior to 2019, be removed from Block 1 “Terminology For Testing Standards” 

and appear as originally presented.

Item LPG-15.1 was removed from Block 1 “Terminology For Testing Standards” and now appears as a 

separate item on the 2022 Interim Meeting agenda.) 

Source: Endress + Hauser Flowtec AG USA

Purpose and Justification:

Amend Handbook 44 to allow field reference standards meters to be used to test and place into service 

dispensers and delivery system flow meters.

This item has been assigned to the submitter for further development. For more information or to provide 

comment, please contact:

Mr. Michael Keilty

Endress + Hauser Flowtec AG

(970) 586-2122, michael.keilty@us.endress.com

The use of transfer standards is recognized in Code sections 3.34 Cryogenic Liquid-Measuring Devices 

Code and 3.38 Carbon Dioxide Liquid-Measuring Devices Code and 3.39 Hydrogen Gas-Measuring 

Devices – Tentative Code. Transfer standard is only defined for testing cryogenic liquid measuring devices. 
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It has been pointed out that the term transfer standard is not correct and that field reference standard meters 

may be more appropriate. See new the Item under Consideration, updated on September 8, 2017.

Field evaluation of LPG meters and CNG dispensers and LNG dispensers is very difficult using volumetric 

and gravimetric field standards and methods. The tolerances for these applications are such that using field 

reference standard meters are more efficient and safer. With CNG and LNG and LPG applications, the 

field reference standard meters are placed in-line with the delivery system as it is used to fill tanks and 

vehicles. The use of field reference standard meters eliminates return to storage issues. The use of field 

reference standard meters is easier and faster compared to the use of traditional field standards. The cost 

of using field reference standard meters and transporting them is much less than the cost of traditional field 

provers and standards.

Recognition in Handbook 44 will enable States to allow field reference standard meters to place systems 

into service and for field enforcement.

Volumetric field provers and gravimetric field proving are susceptible to environmental influences. The 

State of Colorado uses a field reference standard meter to test propane delivery truck meters. The State of 

Nebraska has used a field reference standard meter to test agricultural chemical meters. Other States have 

asked that there be recognition in HB44 in order for their State to allow the use of field reference standard 

meters.

In some applications, field reference standard meters are not more accurate than the meters used in the 

application. For that reason, longer test drafts and possibly more tests may need to be run.

The State of California is purported to have conducted a short study of field reference standard meters in 

the past. The conclusion did not lead to wide adoption of the practice. 

Section 3.37 Mass Flow Meters user requirement U.R.3.8. Return of Product to Storage, Retail Compressed 

Natural Gas Dispensers requires that the natural gas which is delivered into the test container must be 

returned to storage. This is difficult and most often not complied with when the test vessel contents are

released to atmosphere. States often have difficulties in remote locations finding suitable field reference 

equipment.

OWM Executive Summary for LPG-15.1 – N.3. Test Drafts.

OWM Recommendation OWM believes that the purpose for this item, as specified by the submitter, 

is better addressed from a technical standpoint in Item Block 8.

• State and industry have a need to use various types of field test standards to evaluate commercial 

devices installed in the marketplace. NIST OWM recognizes the need to use various standards to 

test commercial devices and support the use of these standards when test data supports its use.

• NIST OWM is also supporting the use of various types of field test standards through the purchase 

of several meters and the collection of data throughout the U.S.

• The purpose statement for Items LPG-15.1 (LPG & Anhydrous Ammonia Liquid-Measuring 

Devices Code) indicates the goal of this items is:

“to amend Handbook 44 to allow field reference standard meters to be used to test and place into 

service dispensers and delivery system flow meters.”
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OWM Executive Summary for LPG-15.1 – N.3. Test Drafts.

• The proposed changes in Items LPG-15.1 suggest changes to the test draft criteria for devices covered 

under this code, which is not necessary to allow field reference standard meters to be used to test and 

place into service dispensers and delivery system flow meters.

• Amongst the concerns raised to the S&T Committee over the proposed changes for LPG-15.1 is that 

it conflicts with existing test draft criteria and confusion over the application of the proposed 

requirement.

• As such, given the long debate over multiple iterations of the proposals, OWM proposes that since 

the purpose of the proposal is to allow field reference standard meters to be used to test and place into 

service dispensers and delivery system, and the responsibility for allowance of these field test 

standards are already addressed in the NIST Handbook 44 Fundamental Considerations and Item 

Block 8 clarifies these responsibilities, that Consideration be given to the proposal in Item Block 8 

which clearly states the responsibility for allowance of field standards along with a new proposal to 

add a general code requirement. 

• Note that Block 8 items clarify what has long been recognized in NIST HB 44 concerning the 

responsibility for acceptance of a standard making changes to specific codes such as those references 

in LPG-15.1 unnecessary and confusing. 

• Additionally, the Committee is aware that a new Form 15 has been submitted by Seraphin for the 

2023 cycle proposing a new General Code paragraph which clearly references the Director’s authority 

as outlined in the Fundamental Considerations.

o This not only avoids the need to specifically reference individual test methods in each specific 

code, it avoids the potential of implying that test methods not specifically referenced in a code 

would not be appropriate.

o G-N.3. Test Methods. – Permissible test methods for verifying compliance of weighing and 

measuring systems with the provisions of the General Code and Specific Codes include, 

but are not limited to, test methods and apparatus that have been approved by the State 

Director of weights and measures as outlined in Appendix A - Fundamental 

Considerations, Section 3. Testing Apparatus.

Table 3. Summary of Recommendations

LPG-15.1 N.3. Test Drafts

V D W A I Notes* Comments

Submitter 

OWM

WWMA 

SWMA 

NEWMA 

CWMA 
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Table 3. Summary of Recommendations

LPG-15.1 N.3. Test Drafts

V D W A I Notes* Comments

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Amend Handbook 44, LPG and Anhydrous Ammonia Liquid-Measuring Devices as follows: 

N.3. Test Drafts. 

N.3.1 Minimum Test - Test drafts should be equal to at least the amount delivered by the device 

in 1 minute at its normal discharge rate. 

(Amended 1982)

N.3.2. Field Reference Standard Meter Test. – The minimum quantity for any test draft shall 

be equal to or greater than the amount delivered in one minute at the flow rate being tested.

(Added 20XX)

NIST OWM Detailed Technical Analysis:

• Although this item has been on the agenda for a number of years, this item was group in a block of 

other similar items then removed from the block and placed back on the NCWM agenda as it originally 

appeared on the agenda. 

• NIST OWM is working with States using Coriolis meters to collect data on the use of these meters as 

standards to test liquid measuring devices. This data will be shared with all regulatory officials to assist 

them with their approval of meters as standards.

• This purpose indicates its intent is to permit the use of field reference standard meters in field testing 

of commercial measuring systems.

• It is not necessary to reference “field reference standards” in a specific NIST HB 44 code in order to 

permit their use.
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• Criteria for assessing the use of a given type of test standard are outlined in NIST HB 44 Appendix A 

Fundamental Considerations and clarified by Item Block 8 and OWM believes that the purpose for this 

item, as specified by the submitter, is better addressed from a technical standpoint in Item Block 8.

• The decision on whether or not to accept a particular test method for use in testing commercial weighing 

and measuring equipment ultimately rests with the regulatory authority.

• NIST OWM and Seraphin developed Block 8 items (GEN-19.1 and OTH-22.1) on the 2022 Annual 

Meeting Report to help clarify and provide additional information on field standard traceability and 

specifications, and the regulatory authority’s responsibility for approval of field standards.

• With regard to the proposed addition of a paragraph N.3.2. Field Reference Standard Meter Test., no 

information or data has been provided to justify that:

 a different test draft size than that specified in N.3.1. Test Draft is necessary in order to use a “Field 

Reference Standard Meter.” 

 the specific criteria of a minimum quantity of “equal to or greater than the amount delivered in one 

minute at the flow rate being tested” is appropriate.

NIST OWM believes this item is not supported with data, in that it lacks data to show that one minute of 

flow would be appropriate. We believe that this data can be collected as data is collected across the country 

to assess field standard meters or the submitter can provide additional data. Also, since the authority to 

accept or reject a meter as a field standard is the responsibility of the regulatory authority, this item is 

inappropriate for its purpose.

• A new Form 15 has been submitted by Seraphin for the 2023 cycle proposing a new General Code 

paragraph which clearly references the Director’s authority as outlined in the Fundamental 

Considerations.

o This not only avoids the need to specifically reference individual test methods in each 

specific code, it avoids the potential of implying that test methods not specifically 

referenced in a code would not be appropriate.

G-N.3. Test Methods. – Permissible test methods for verifying compliance of weighing and measuring 

systems with the provisions of the General Code and Specific Codes include, but are not limited to, 

test methods and apparatus that have been approved by the State Director of weights and measures 

as outlined in Appendix A - Fundamental Considerations, Section 3. Testing Apparatus. 

Summary of Discussions and Actions:

The Committee initially considered a proposal to modify paragraph N.3. Test Drafts and to add a new 

paragraph N.3.2. Transfer Standard Test as shown below. Note that, in Fall 2016, Mr. Keilty provided an 

update to this proposal as shown in the Item under Consideration above.

N.3. Test Drafts. – 

N.3.1 Minimum Test - Test drafts should be equal to at least the amount delivered by the device 

in one minute at its normal discharge rate. 

(Amended 1982)
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N.3.2. Transfer Standard Test. – When comparing a meter with a calibrated transfer 

standard, the test draft shall be equal to at least the amount delivered by the device in 2 

minutes at its maximum discharge rate. 

The submitter recommended that NIST update EPO 28 for CNG dispensers and EPO 26 for LPG Liquid 

Measuring Systems to include transfer standard meter tests. NIST Handbook 105-4 should also be revised 

to specifically address the transfer standard meter and the requirements for use.

The S&T Committee might also consider amending Sections 3.30 Liquid-Measuring Devices Code and 

3.31 Vehicle-Tank Meters Code to allow transfer standard meters.

The Committee received written comments on all items in Block 4 and Block 5, as well as LPG-4 and 

MFM-2 emphasizing the need for there to be more study and discussion of the issues to assess the 

ramifications of all the proposed changes. The Committee also received written comments from the SMA 

that it looks forward to further information on these items and stating that it is important to be consistent in 

our use of terms across multiple sections of NIST Handbook 44. The Committee agreed to carryover this 

group of items on its 2019 agenda to allow for further discussion and development of these proposals.

At the 2019 NCWM Interim Meeting the Committee decided to combine the items on the agenda dealing 

with the issue of transfer standard (including items already combined into blocks) into one block. Block 1 

(New) of the Interim Meeting report now includes Gen-3, Block 1 (original items from the 2019 interim 

agenda that appeared under Block 1), Block 2, LPG-3 and MFM-5, which were all separate items and 

blocks of items on the S&T Committee’s 2019 Interim Meeting agenda (NCWM Publication 15). Agenda 

items Gen-3, Block 1, Block 2, LPG-3, and MFM-5 are listed separately on the Interim agenda with a note 

added beneath each individual item referring the reader to the New B1 items. All items under this New B1 

have retained the same numbering system for ease in referring to the appendix for discussion on each item.

At the 2019 NCWM Annual Meeting: Mr. Brett Gurney (NCWM Chairman) commented regarding the 

formation of a Task Group assigned to further develop this block proposal. The TG is charged with 

providing definitions for various types of standards (transfer, field, reference, etc.) as well as the criteria to 

be met by these types of standards. The completion date given to the TG is July 2021. The Committee 

agreed to the Assigned status for this block of items and looks forward to hearing updates from the TG. the 

Chair of the Task Group was:

Mr. Jason Glass

Kentucky Department of Agriculture

(502) 573-0282, jason.glass@ky.gov

At the 2020 NCWM Interim Meeting the Field Standard TG Chair Glass reported that the Task Group met 

prior to the Interim Meeting and has begun discussion of the items under Block 1. Mr. Glass stated that biweekly teleconference meetings were scheduled and that the group was optimistic but had significant work 

to accomplish. 

Mr. Russ Vires (SMA) supports the Scale item, SCL 18.1; in this block, Mr. Dimitri Karimov (Meter 

Manufacturers Association) supports the Task Group activities, Mrs. Tina Butcher (NIST OWM) was 

encouraged with the progress on terminology and provided an update on the Mass Flow Meter testing 

reporting that field testing was conducted October 28 to November 1, 2019 and that State and Industry 

participation included Colorado, Florida, Oregon, Emerson, and Tulsa Gas Technology. 
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Mr. Kurt Floren (Los Angeles County, California) raised concerns with GEN-19.1. regarding the definition 

of “Standard, Field” and its reference to “stable” standards and how long a standard is expected to be stable, 

which is typically 1-year, for which he believes should be longer. Mr. Floren also questioned the statement 

in the definition “tested over a range of environmental and operational conditions that the measuring devices 

is used...” Mr. Floren noted that he was unsure if all laboratories will have the capabilities to test over this 

wide range of conditions. Mr. Floren also expressed concerns with the definition “Standard, Transfer” 

citing that this standard may not meet the fundamental considerations requirement for standards over a long 

period of time or wide range of environmental conditions. 

Mr. Steve Harrington (Oregon) echoed Mr. Floren’s comments. Field Standard TG Chair Glass responded 

that these are concerns of the TG and these issues will be discussed and considered as the TG develops 

these items. 

During the Committee’s work session, the Committee agreed that this item should remain an Assigned 

item.

At the 2021 NCWM Interim Meeting the NCWM Field Standard TG Chair, Mr. Jason Glass (Kentucky) 

provided an update on the Task Group activities. Mr. Glass reported that the Field Standard Task Group is 

following the activities of the NIST Master Meter Project and that the Task Group reviewed API 

specifications for use of master meters as a standard and a test protocol that will be used to ensure uniformity 

in collecting data on master meters used as field standards. He also reported that the TG does not have a 

recommendation for this item. Mr. Glass also reported that he would be stepping down as the TG Chair. 

Mr. Mike Keilty (Endress+Hauser AG) thanked Chair Glass and the TG for their work and requested that 

Block 1, LPG-15.1, N.3. and Block 1 MFM-15.1, N.3 be removed from Block 1 items and to allow those 

items to move forward separate from the other Block 1 Items. Mr. Keilty stated that similar language was 

added to the Hydrogen code and that the proposed language in LPG-15.1 N.3. and MFM-15.1, N.3 will 

allow for the recognition of master meters as field standards. Mr. Henry Oppermann (WM-Consulting), 

stated that data is needed to ensure that master meters can be used over a range of conditions. Mr. Bob 

Murnane (Seraphin) stated that jurisdictions have the ability to use meters and that Block 1 LPG-15.1, N.3 

and Block 1 MM-15.1, N.3 should remain in Block 1 until data is available to support the use of master 

meters as a standard. Mr. Keilty mentioned that there has been useful dialog regarding master meters in 

the TG, but that he is concerned that the TG is not close to deciding and he expressed concerns with the 

TG’s focus on the NIST Master Meter Project. Mrs. Tina Butcher (NIST OWM) provided an update on 

the NIST Master Meter Project and noted that States have the regulatory powers to accept or reject a 

standard. She also mentioned that NIST is working with States to collect data needed to assess master 

meters and preliminary testing was conducted and data was collected on CNG at Tulsa Gas Technology’s 

facility in fall 2019. Ms. Diane Lee (NIST OWM) noted that NIST OWM feels that it is premature to add 

more language to the NIST Handbook 44 on master meters without data to support its use.

During the Committee’s work session, the Committee agreed to keeps all items in Block 1 and that this 

item should remain with an Assigned status.

At the 2021 NCWM Annual Meeting Mr. Glass reported that he would be stepping down as the Field 

Standard TG Chair. The Committee heard updates from members of the Task Group during open hearings. 

Mr. Mike Keilty (Endress+Hauser AG) noted that two of the items had been on the agenda since 2015 and 

requested that they be removed from the block and recommended recognizing the use of master meters. 

Other comments were to keep the items together until data is analyzed from the NIST Field Reference 

Standard Work Group to support the use of master meters but that if some items were removed from the 

block, all items should be removed from the block. Based on comments heard during the 2021 Annual 

Meeting, the S&T Committee recommended that all items that were included in Block 1 “Terminology For 
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Testing Standards” that originally appeared as a separate item or a separate block of items on the S&T 

agenda in and prior to 2019, be removed from Block 1 “Terminology For Testing Standards” and appear 

as originally presented. 

At the 2021 Committee work session, the Committee recognized that the Task Group has accomplished all 

it is able to at this point and is recommending the Task Group be disbanded and will make said 

recommendation to the NCWM Chairman. The Committee agreed to break all items in Block 1 into 

individual items and designate them all as Developing. The Committee thanks the Task Group and its 

members for their work. 

At the 2022 NCWM Interim meeting, the Item under Consideration is provided below: 

N.3. Test Drafts. 

N.3.1 Minimum Test - Test drafts should be equal to at least the amount delivered by the device 

in 1 minute at its normal discharge rate. 

(Amended 1982)

N.3.2. Field Reference Standard Meter Test. – The minimum quantity for any test draft shall 

be equal to or greater than the amount delivered in one minute at the flow rate being tested.

(Added 20XX)

Mr. Keilty shared a presentation on field standard meters during open hearings relevant to both LPG 15.1 

and MFM 15.1. The intent of the presentation was to describe initial and ongoing calibration traceability, 

compare OIML tolerances vs NIST Handbook 44, describe the benefits and show examples of master 

meters. An abbreviated copy of the presentation is available on the NCWM website in the interim meeting 

documents archive. Mr. Keilty commented that he believes LPG 15.1 and MFM 15.1 are fully developed 

and should receive voting status for the annual meeting. He has updated the proposal to exclude the term 

“reference” from “field reference standard meter test”, as shown above. He requests that the Committee 

provide specific guidance if a developing status is assigned. A comment from industry (Bob Murnane – 

Seraphin) stated that N.3.2 in the proposal conflicts with the current code which states normal test drafts 

must be at least one minute at the maximum discharge flow rate of installation conditions. The current 

wording allows for a test to be conducted at any flow rate for one minute. There was concern from a 

regulator (Mr. Charles Stutesman, Kansas) echoing these concerns. Ms. Diane Lee (NIST) requested that 

more data be made available so that NIST is able to compare worldwide data against test data compiled 

within the U.S. by NIST. Mr. Mahesh Albuquerque (Colorado) expressed support for this item to receive 

Voting status. Mr. Marc Butler (Emerson Micro Motion) expressed confusion at the two notes, thinking 

that perhaps they conflicted with each other; are they both needed or are they independent? Mrs. Tina 

Butcher (NIST OWM) expressed that she recognizes the use and importance of master meters, but is 

concerned with the purpose of this item. Mrs. Butcher suggested that the statement for use be reworked as 

test draft criteria is so critical. Mrs. Butcher recommended and offered NIST OWM assistance on this item.

During the S&T Committee work session, the Committee recognized the submitters desire that a voting 

status be recommended but determined that there were too many concerns and confusion expressed. The 

Committee recommends that the submitter develop the item further by aligning language to existing 

language in Handbook 44, clarifying the purpose to help avoid confusion of the new code on new 

equipment, and reaching out to NIST OWM or other industry or regulatory officials for feedback.
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Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Michael Keilty (Endress + Hauser): in 2014 - he submitted a Form 15 to edit content and add N.3.2. It 

was set to Developing. Several W/M officials have supported this. Asks that this be a Voting item in 2022.

Mr. Bob Murnane (Seraphin): this is to allow a field reference standard meter; this definition does not 

currently exist. Recommends that this be withdrawn so that the definitions can be worked out.

Ms. Diane Lee (NIST OWM): this item was put forth in 2015 - purpose was: to accept a specific master 

meter in the field. It’s not necessary to ref. field ref. standards in specific code. NIST and States are 

working to collect data to see if master meters can be used. States are to determine which standards are to 

be used in the states. N.3.2 was an issue. There was no information as to justify a different test draft size 

than was specified in N.3 or if it is necessary to use a field reference meter.

Mr. Bruce Swice (National Propane Gas Association): he lent support to this discussion (master meters). 

It would be nice to have something in HB 44 to assist in uniformity.

Mr. Michael Keilty (Endress + Hauser): to address Ms. Lee: he agrees and disagrees. Agree: it was stated 

that jurisdictions are responsible for their own equipment, however, he was told by States that they need 

something in HB 44 to tell them what should be used. Again - wants Voting on this item in 2022.

The WWMA S&T Committee recommends the status remain Developmental. The Committee recommends 

that consideration be made that this item be included in Block 5, as they refer to the same terminology in 

HB 44. A letter was submitted to the Committee by Mr. Michael Keilty (Endress + Hauser) and will be 

posted to the NCWM website. NIST OWM also submitted analysis on this item which can be found at the 

following link on the NCWM website: https://www.ncwm.com/annual-archive

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, Mr. Oppermann (Seraphin) supports the Withdrawal of 

this item because it is unnecessary, as master meters can already be recognized as field standards. 

Mr. Keilty (Endress+Hauser), the submitter of this item, supports striking the words “Reference” and 

“Meter” from “N.3.2. Field Reference Standard Meter Test.” In this proposal, and moving it forward as a 

Voting Item. 

This Committee feels that the item is fully developed and is looking forward to seeing more data on the 

performance accuracy of master meters by the states that are currently using these devices. 

This Committee recommends this item move forward as a Voting item with the editorial changes requested 

by Mr. Keilty. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing, the following comments were heard.
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Mr. Michael Keilty (Endress + Hauser Flowtec), as the submitter of this item, gave a history of the item 

from 2015 and is recommending voting status with changes striking text seen below. Mr. Keilty also has 

submitted comments which are available on the NCWM website. 

N.3.2. Field Reference Standard Meter Test. – The minimum quantity for any test draft shall 

be equal to or greater than the amount delivered in one minute at the flow rate being tested.

(Added 20XX)

Mr. Henry Opperman (Seraphin) commented that the latest information was not reviewed and changes are 

immature as data has not been produced to justify this. And he added that NIST OWM is currently 

undertaking a study to gather data and this data could help provide justification for this item and 

recommends further development.

Mr. Rick Harshman (NIST OWM) and Bob Murnane (Seraphin) also recommended further development.

At the 2022 NCWM Annual Meeting Open Hearing Mr. Bob Murnane (Seraphin) commented that he does 

not believe this item is fully developed and recommended that the committee consider withdrawing the 

item. Mr. Murnane read from submitted comments. Of note, MR. Murnane indicated that under the 

Fundamental Considerations in HB 44, the State Director has the authority to evaluate standards for use in 

certifying meters and the fear is that if this proposal goes through, the handbook would have to be changed 

for each new technology. Mr. Murnane explained that several states have already evaluated meters to use 

as standards and determined them to be accurate to use. If this proposal is adopted, Mr. Murnane believes 

that it would take powers away from State Directors to evaluate and use these standards. Mrs. Tina Butcher 

(NIST OWM) commented that the concept of master and reference meter is to use the meter as a standard 

in place of provers. The authority to use them rests with the State Director, however, there needs to be a 

method to ensure accuracy. Mrs. Butcher mentioned several alternatives as outlined in the submitted NIST 

analysis.

During the open hearings, comments were heard from the floor regarding this item and MFM-15.1 at the 

same time.

After hearing comments from the floor, the Committee does not believe the item is fully developed, even 

though the item has been on the agenda for several years. The Committee recommended that the item be 

withdrawn.

Central Weights and Measures Association 

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mr. 

Michael Keilty (Endress+Hauser Flow) asked that the item be moved to voting and if not, asks for 

suggestions from the Committee on how to improve item. Dr. Henry Opperman (Weights and Measures 

Consultants) does not support the item. Says it does not explain mass flow meter as a standard and where 

is the data that supports this item. Mrs. Tina Butcher (NIST OWM) agreed with comments from Dr. Henry 

Opperman. Mr. Charles Stutesman (Kansas) agreed with Mrs. Butcher but understands the submitting of 

this proposal and should be moved as a Voting item.

CWMA S&T Committee recommends this item moving forward as a Voting item. 

During the 2022 Annual Meeting Open Hearing Mr. Micheal Keilty (Endress+Hauser) presented 

calibration data at the 2022 NCWM Interim Meeting. No recommendations from NCWM have been 

released. Recommended a minor change that re-includes the word “meters” because it was confusing how 
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to apply testing requirements. Both items explain the amount of test drafts that differ from other volume 

standards. Field standard meter provides flexibility for use across many different products and densities. 

Field Standards are tested against OIML and API standards using gravimetric methods that are NIST 

traceable. Accuracy and repeatability are long term, it is a maintenance free system with no moving parts. 

These systems save time and space, contain embedded diagnostics, are easy to use, and easy to maintain. It 

is easy to train the operator of these systems. NMi has issued a test report on this system. Various setups 

can be mounted to a rack and easily transported. SWMA and CWMA recommended this item move forward 

as voting item in the 2021 Interim Meeting. Recommending placing as Voting today and move forward 

for a vote this week.

Mr. Jan Konijnenburg (NIST OWM): State and industry have a need to use various types of field test 

standards to evaluate commercial devices installed in the marketplace. NIST OWM recognizes the need to 

use various standards to test commercial devices and support the use of these standards when test data 

supports its use.

The NIST OWM is also supporting the use of various types of field test standards through the purchase of 

several meters and the collection of data throughout the U.S.

The purpose statement for Items LPG-15.1 (LPG & Anhydrous Ammonia Liquid-Measuring Devices 

Code) indicates the goal of this items is:

“to amend Handbook 44 to allow field reference standard meters to be used to test and place into service 

dispensers and delivery system flow meters.”

The proposed changes in Items LPG-15.1 suggest changes to the test draft criteria for devices covered under 

this code, which is not necessary to allow field reference standard meters to be used to test and place into 

service dispensers and delivery system flow meters.

Amongst the concerns raised to the S&T Committee over the proposed changes for LPG-15.1 is that it 

conflicts with existing test draft criteria and confusion over the application of the proposed requirement.

As such, given the long debate over multiple iterations of the proposals, OWM proposes that since the 

purpose of the proposal is to allow field reference standard meters to be used to test and place into service 

dispensers and delivery system, and the responsibility for allowance of these field test standards are already 

addressed in the NIST Handbook 44 Fundamental Considerations and Item Block 8 clarifies these 

responsibilities, that Consideration be given to the proposal in Item Block 8 which clearly states the 

responsibility for allowance of field standards along with a new proposal to add a general code requirement. 

(See Item Block 8 of the NIST OWM Analysis for the S&T Annual Meeting.)

Mr. Mike Johnson (Nebraska) supports this item and agrees with Mr. Keilty. Nebraska has had great 

success over the last 18 years using this method. Nebraska has over 300 mass flow meters and gravimetric 

testing isn’t practical.

Bob Murnane (Seraphin): the stated purpose on these proposals to amend Handbook 44 and to allow field 

standards meters to be used to test and place into service dispensers and delivery system flow meters. The 

current language adding N.3.2., has nothing to do with the purpose statement nor does have any effect at 

all on whether meters can be accepted or used as field standards.

Handbook 44 under fundamental considerations already allows for the use of field standards and /or 

equipment, as approved by the Director. There are already numerous meters in the field being used as 

standards that have been approved by State Directors under these fundamental considerations.
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Note: Seraphin has a proposal, item OTH-22-1 that supports the Directors authority.

What is the reason and justification for N.3.2 when we already have a test draft size in N.3.1? What data 

and analysis has been provided regarding the uncertainties associated with the field standard meters and the 

sizes of the drafts proposed in N.3.2.? The proposal MFM-15.1., N.3.2 would impose constraints on the 

capability of the W&M officials to test mass flow meters.

Under the current paragraph N.3., W&M officials can conduct tests at any flow rate for any quantity that is 

equal to or greater than minimum measured quantity (MMQ) specified by the manufacture of the meter. 

Under the proposed N.3.2., the minimum size of the test drafts must be greater than or equal to the quantity 

delivered in one minute at the flow rate at which the test is being conducted. Depending upon the 

measurement application and the test equipment available, this could substantially increase the size of the 

required test drafts for almost all flow rates for mass flow meters.

Example: Recently there was CNG testing performed in Colorado. The test drafts were for 1/3 of the 

capacity of the test cylinder (as specified in the EPO) and it took less than one minute to complete. In this 

case the proposed change to the size of the test draft on MFM15.1. would have prevented Weights & 

Measures officials from conducting the tests.

Weights and Measures officials should be able to test mass flow meters using any test draft size, equal to 

or greater than the MMQ over the range of flow rates. I did not do an extensive review but I did find six 

NTEP Certificates of Conformance that would not be able to be tested using the proposed MFM-15.1., 

N.3.2. What happens to them?

If the proposal were adopted with its current purpose statement it could be interrupted that every meter is 

acceptable for use as a field standard. How do you know which meters are acceptable for use as a field 

standard and which ones are not? For example, if a meter is brought into the United States from another 

country, can it be used as a field standard. This proposal will cause confusion for both Weights and Measure 

officials and testing companies.

Additional Notes:

NIST and Seraphin requested Mr. Mike Keilty’s participation in a meeting on these items and he declined. 

There has been a total of six changes to the wording on these items since they were introduced. Again, I 

would like to remind the Committee that States are already using meters as field standards and this is 

permitted by the existing fundamental considerations. There is no need for these proposals. Seraphin Test 

Measures opposes items LPG-15.1. and MFM-15.1 and asks the Committee to withdraw this item from 

consideration. Comment: years on an agenda are not part of criteria for deciding if an item should be made 

a Voting item.

Mr. Charlie Stutesman (Kansas): Regarding Fundamental Considerations: states already have the ability 

to decide what’s allowed. It already falls within The Director’s authority, but we have other existing codes 

in HB 44 which reference transfer standards and specifically allowing their use for testing particular 

devices. The NIST EPOs are still in draft status and are a resource tool only. Flow rate will be more 

important going forward as gravimetric testing becomes more prevalent. Recommends sending to Voting 

status. Does this only apply to mass flow meters as the standard? NIST stated they are using Coriolis 

meters. But the decision to use non-mass flow meters as the field standard rests with The Director. This 

will apply to any meter technology, not just mass flow meters.
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Mr. Michael Keilty (Endress+Hauser): Other codes in HB 44 contain advice on specific test drafts when 

using transfer standards. These proposals give test draft advice to handle slow flow devices. The EPO for 

CNG testing uses small containers but the EPO can be changed.

Mr. Ivan Hankins (Iowa) – Mr. Hankins has witnessed these tests using these transfer standards at multiple 

flow rates and drafts. It took much less time. This technology will allow jurisdictions to test at a quicker 

pace, using less staff. Supports this proposal.

Mr. Bob Murnane (Seraphin) – Mr. Murnane questioned if the draft size is merely a suggestion.

The CWMA S&T Committee recommends this moves forward as a Voting item.

LPG-22.2 W S.2.6. Zero-Set-Back Interlock, for Stationary Customer-Operated Retail MotorFuel Devices, Electronic. 

Source: U-Haul International, Inc.

Purpose and Justification:

The proposal will address practical issues that propane marketers encounter when trying to comply with 

the zero setback requirements for propane stationary and truck-mounted meters in Handbook 44.

Motor fuel, within the context of NFPA 58, refers to any container that has the potential to provide propane 

to fuel an engine. This can include a multitude of DOT cylinders and ASME containers that are not for the 

propulsion of an automobile. Current mechanical meter technology utilized in a standard propane dispenser 

for the filling of portable containers, such as those utilized in NFPA 58 for motor fuel applications or those 

that do power automobiles, are not capable of being equipped with a zero-set-back interlock and the 

technology will not be potentially available until 2022, per meter manufacturers.

NFPA 58 currently does not allow the public to refuel its automobiles. All automobiles or other containers 

must be filled by a specially trained employee. A proposed change has been introduced for consideration 

in the 2023 edition of NFPA 58 that would permit public refueling of automobiles as long as the dispensing 

system meets very specific safety requirements, including a specialized nozzle, and is furnished with visible 

instructions. Upon the acceptance of this new public refueling allowance the propane industry agrees that 

Zero-Setback-interlocks are needed. These public self-service automotive dispensing systems will be listed 

to Underwriters Laboratories Standard 495 and will be dedicated to the filling of motor vehicles.

Most propane dispensed is for purposes other than motor-fuel. Pursuant to NFPA 58, this is accomplished 

by a trained and certified employee dispensing propane, typically using mechanical meters, into cylinders 

and tanks. The employee is trained and required to manually reset the meter to zero after each transaction 

and verify the meter is reset prior to initiating a subsequent transaction. This has been and remains an 

accepted practice for dispensing propane. This process is the industry standard for approximately 97 % of 

all propane used in the United States. See U.S. Department of Energy, Alternative Fuels Data Center 

afdc.energy.gov/fuels/propane_basics.html. 

Unlike traditional motor-fuel, such as gasoline or diesel, customers cannot currently dispense propane into 

their vehicles. If NFPA 58 is amended to allow customers to dispense their own propane into their vehicles 

and the demand for propane as motor-fuel increases, the market will drive retailers to provide electronic 

customer-operated retail motor-fuel devices to meet the demand and customer expectations for efficient 

and expedient fueling transactions. At that time, the electronic customer-operated motor-fuel devices will 
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certainly need to incorporate an automatic zero-set-back interlock. It is simply too early in the process to 

effectively force mechanical retail motor-fuel devices out of the market for such a small percentage of the 

retail propane market (approximately 3 %).

It is difficult to counter the argument above. Opponents of this proposed change may argue that automatic 

zero-set-back interlocks are necessary to prevent customers being overcharged for propane.

The submitter requested that this be a Voting Item in 2022.

OWM Executive Summary for LPG-22.2 – S.2.6. Zero-Set-Back Interlock, for Stationary 

Customer-Operated Retail Motor-Fuel Devices, Electronic.

OWM Recommendation: No recommendation. This item was withdrawn following the 2022 Interim 

Meeting.

Table 3. Summary of Recommendations

LPG-22.2 S.2.6. Zero-Set-Back Interlock, for Stationary Customer-Operated Retail Motor-Fuel 

Devices, Electronic.

V D W A I Notes* Comments

Submitter 

OWM

WWMA 

SWMA 

NEWMA

No comments received because this item 

was withdrawn following the 2022 Interim 

Meeting.

CWMA 

No comments received because this item 

was withdrawn following the 2022 Interim 

Meeting.

NCWM

Letters of Support Letters of Opposition Notes

Industry

• Letter from 

Endress+Hauser (10-

07-2021)

• Endress+Hauser Slides 

(01-11-2022)

• Endress+Hauser Letter 

to CWMA (05-12-

2022)

• Comments from 

Seraphin (09-27-2016)

• Comments from 

Seraphin (06-23-2017)

• Comments from 

Seraphin (07-02-2018)

• Comments from 

Seraphin Test Measure 

Co. (06-17-2022)

Manufacturers

Retailers and Consumers
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Table 3. Summary of Recommendations

LPG-22.2 S.2.6. Zero-Set-Back Interlock, for Stationary Customer-Operated Retail Motor-Fuel 

Devices, Electronic.

V D W A I Notes* Comments

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Liquefied Petroleum Gas and Anhydrous Ammonia Liquid-Measuring Devices Cod 

as follows: 

S.2.65.2. Zero-Set-Back Interlock for Stationary Customer-Operated Retail Motor-Fuel Devices - A 

device shall be constructed so that:

(a) after a delivery cycle has been completed by moving the starting lever to any position that shuts 

off the device, an automatic interlock prevents a subsequent delivery until the indicating 

elements and recording elements, if the device is equipped and activated to record, have been 

returned to their zero positions;

(b) the discharge nozzle cannot be returned to its designed hanging position (that is, any position 

where the tip of the nozzle is placed in its designed receptacle and the lock can be inserted) 

until the starting lever is in its designed shut-off position and the zero-set-back interlock has 

been engaged; and

(c) in a system with more than one dispenser supplied by a single pump, an effective automatic 

control valve in each dispenser prevents product from being delivered until the indicating 

elements on that dispenser are in a correct zero position.

[Retroactive Nonretroactive as of January 1, 2017 2023] 

(Added 2016, Amended 2022 20XX) 

NIST OWM Detailed Technical Analysis: 

This proposal provides changes to the title of Zero Set-back Interlock for Stationary Retail Motor-Fuel 

Devices by adding “Consumer Operated” Retail Motor Fuel Dispenser, “Electronic” in the LP-Gas code. 

In the submitter’s justification it is noted that a proposed change was introduced in consideration for 

proposed changes introduced in the 2023 edition of NFPA to permit public refueling of automobiles with 

LP-Gas, which is currently not allowed; currently automobiles and containers must be filled by a specially 

trained employee. These public self-service automotive dispensing systems will be dedicated to fueling 

motor vehicles. As such the industry agrees that zero set-back interlock is needed for these devices. 

The current requirement for Zero-Setback Interlock for Stationary Retail Motor Fuel Devices in the 2022 

version of NIST HB 44 Section 3.32 LPG and Anhydrous Ammonia Liquid Measuring Devices Code has 
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requirements for electronic stationary meters and for analog stationary retail motor fuel dispensers. Both 

paragraphs apply to either customer or employee operated. Adding “Customer-Operated” and 

“Electronic” does not appear to be necessary. Both are covered under the existing requirements. 

- It appears that the most current edition (2022 edition) of NIST HB 44 was not used when this 

proposal was created.

- The paragraph that is numbered S.2.6 in the proposal is S.2.5.2 in the 2022 version of NIST HB 

44.

- NIST HB 44 does not typically make a distinction as to who operates the device and currently 

S.2.5.2 applies to both electronic and analog devices and as such the proposed changes in this item 

are already addressed in S.2.5.2.

- The proposed change to the paragraph S.2.6 to become a retroactive requirement would require that 

manufacturers retrofit the equipment or get new equipment for all equipment. This paragraph 

originally was non-retroactive as of January 1, 2017. 

- This proposal appears to be redundant. The requirements for zero-set-back interlock already apply 

to electronic retail motor fuel devices, regardless of whether or not they are customer or owner 

operated. 

- Additional discussion may be needed as to the intent of this proposal. 

Summary of Discussions and Actions:

At the 2022 Interim Meeting some were in support of this item and others suggested that this item be 

combined with LPG 22.3. NIST OWM provided comments and noted that the proposed changes in this 

item were not based on the current edition of NIST HB 44 and would need to be updated per the current 

NIST HB 44 code requirements. Following the 2022 Interim meeting this item, LPG-22.2, was withdrawn 

and the submitter worked with the submitter of item LPG-22.3 in developing that proposal.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Dwight Farr (U-Haul Program Manager): they proposed this amendment. The majority of propane 

meters are mechanical - this forces them to switch to electronic. He wants this to only pertain to electronic 

meters. This will affect the infrastructure growth. This will deter alt. fuel options (sites just will not sell 

LPG as retail fuel instead of switching to electronic). Customer cannot dispense their own LPG - has to be 

a specially trained associate. Setting back every time a single customer brings in multiple tanks will be 

detrimental to the customer. This only applies to 3 % of his customers. Wants this to be a Voting item next 

year.

Mr. Bruce Swiecicki (National Propane Gas Association): supports this proposal as stated. This will go a 

long way towards fixing the problem.
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Ms. Cadence Matijevich (Nevada): Question for submitter: retroactive status?

Mr. Dwight Farr (U-Haul Program Manager): retroactive to 2017 - law was established at that year.

Ms. Cadence Matijevich (Nevada): the way it is written, it will not suffice. 

Mr. Dwight Farr (U-Haul Program Manager): if it needs to be changed, so be it.

The WWMA S&T Committee recommends based on testimony heard in open hearings and input from the 

NIST advisors during the work session that this item be assigned a Developing status. The Committee also 

recommends that the submitters of LPG-22.2 and LPG-22.3 combine their efforts to develop one of the 

items with consideration to the 2022 version of NIST HB 44.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, Mr. Steven Benjamin (North Carolina) stated that he is 

opposed to this item, because he feels it will allow device manufacturers to cut corners on “full service” 

devices. 

Mr. Tim Chesser (Arkansas) opposes this item. He stated that it was a bad item, seemed incomplete, and 

recommended it be withdrawn. 

This Committee agrees that the item could allow subpar devices to be put into commerce, that the item 

itself is incomplete, and recommends this item be Withdrawn. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearings, no comments were heard on this item. 

The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status. 

During the 2022 Annual Meeting Open Hearing no comments were received because this item was 

withdrawn. 

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard no comments from the floor. The 

Committee received updated proposal to S.2.5. and S.2.6 from Mr. Bruce Swieciki (National Propane Gas 

Association) because technology won’t be available till 2022 per manufacturers.

CWMA S&T Committee recommends item move forward as a Developing item.

During the 2022 Annual Meeting Open Hearing no comments were received because this item was 

withdrawn. 
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LPG-22.3 D S.2.5. Zero-Set-Back Interlock, Stationary and Vehicle Mounted Meters, 

Electronic., S.2.6. Zero-Set-Back Interlock, Vehicle Mounted Meters, Electronic., 

and S.2.67. Zero-Set-Back Interlock for Stationary Self-Operated Retail MotorFuel Devices.

Note: The Item under Consideration has been updated since the 2022 Interim Meeting. The current item 

is a combined effort of the National Propane Gas Association and U-Haul International, Inc. 

Source: National Propane Gas Association

Purpose and Justification:

The proposal will address practical issues that propane marketers encounter when trying to comply with 

the zero setback requirements for propane stationary and truck-mounted meters in NIST Handbook 44.

National Propane Gas Association:

This proposal was developed by the National Propane Gas Association’s Technology, Standards and Safety 

Committee, a volunteer organization comprised of 2500+ members, including propane retail marketers and 

others providing products or services to the propane industry.

In S.2.5, the removal of the vehicle mounted meters from this two-minute requirement is necessary as the 

initiation of a vehicle mounted meter is performed at the truck prior to moving the delivery hose to the 

customer tank, sometimes as far as 150 feet from the meter, or in installations with multiple containers that 

may require continued adjustment of containers or delivery hose to complete a delivery. This configuration 

can lead to periods of up to 5 minutes between initial meter engagement and first container filling or 

between containers being filled on a single delivery.

In revised S.2.6, we are proposing that vehicle mounted meters be allowed periods between meter 

engagement and product flow of greater than 2 minutes prior to automated time out initiation. A fiveminute period is more practical as the initiation of a vehicle mounted meter is performed at the truck prior 

to moving the delivery hose to the customer tank, sometimes as far as 150 feet from the meter, or in 

installations with multiple containers that may require continued adjustment of containers or delivery hose 

to complete a delivery. The configuration on a typical bobtail can lead to periods of up to 5 minutes between 

initial meter engagement and first container filling or additionally periods of greater than two minutes can 

transpire between containers being filled on a single delivery.

Addressing proposed new S.2.7, motor fuel, within the context of NFPA 58, refers to any container that has 

the potential to provide propane to fuel an engine. This can include a multitude of DOT cylinders and 

ASME containers that are not for the propulsion of an automobile. Current mechanical meter technology 

utilized in a standard propane dispenser for the filling of portable containers, such as those utilized in NFPA 

58 for motor fuel applications or those that do power automobiles, are not capable of being equipped with 

a zero-set-back interlock and the technology will not be potentially available until 2022, per meter 

manufacturers.

NFPA 58 does not currently explicitly allow the public to refuel its automobiles. All automobiles or other 

containers must be filled by a specially trained employee. A proposed change has been introduced for 

consideration in the 2023 edition of NFPA 58 that would permit public refueling of automobiles as long as 

the dispensing system meets very specific safety requirements, including a specialized nozzle, and is 

furnished with visible instructions. Upon the acceptance of this new public refueling allowance the propane 

industry agrees that Zero-Setback-interlocks are needed. These public self-service automotive dispensing 
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systems will be listed to Underwriters Laboratories Standard 495 and will be dedicated to the filling of 

motor vehicles.

In view of the above information, existing dispenser systems that may only be utilized by qualified trained 

employees should be permitted to continue operations with the existing meter technology and should not 

be required to include Zero-Set-Back Interlocks. This should include when the dispenser is removed from 

one location and installed in another, as long as the original meter remains functional. Existing cabinetry 

and controls utilized in a standard dispenser cabinet generally include non-digital meters and no electronic 

controls with the exception of a single switch that operates the pump. These simplistic designs are still 

effective and should not be prohibited from use in future (new) installations in which the transfer process 

is attended by trained personnel. Limiting the scope of this section will allow attended dispenser operations 

which are primarily utilized for filling of portable containers to remain consistent in design and 

construction. Current use of this technology has not resulted in any known impact to the consumer or overcharge situations. The term “self-operated” is used in other locations in Handbook 44 and would include 

electronic dispensing devices and meters, which would then be consistent with the prior two sections that 

are limited to electronic meters.

It is difficult to counter the arguments above. The sheer difficulties that a service person can encounter 

when a wet hose must be carried over terrain fairly long distances between receiving containers should be 

sufficient justification to approve this proposal. The counter argument to new S.2.7 would be that the 

customer may not be able to view the meter to ensure it is set back to zero. The submitter requested that 

this be a Voting Item in 2022.

U-Haul International, Inc.

Motor fuel, within the context of NFPA 58, refers to any container that has the potential to provide propane 

to fuel an engine. This can include a multitude of DOT cylinders and ASME containers that are not for the 

propulsion of an automobile. Current mechanical meter technology utilized in a standard propane dispenser 

for the filling of portable containers, such as those utilized in NFPA 58 for motor fuel applications or those 

that do power automobiles, are not capable of being equipped with a zero-set-back interlock and the 

technology will not be potentially available until 2022, per meter manufacturers. 

NFPA 58 currently does not allow the public to refuel its automobiles. All automobiles or other containers 

must be filled by a specially trained employee. A proposed change has been introduced for consideration 

in the 2023 edition of NFPA 58 that would permit public refueling of automobiles as long as the dispensing 

system meets very specific safety requirements, including a specialized nozzle, and is furnished with visible 

instructions. Upon the acceptance of this new public refueling allowance the propane industry agrees that 

Zero-Setback-interlocks are needed. These public self-service automotive dispensing systems will be listed 

to Underwriters Laboratories Standard 495 and will be dedicated to the filling of motor vehicles.

Most propane dispensed is for purposes other than motor-fuel. Pursuant to NFPA 58, this is accomplished 

by a trained and certified employee dispensing propane, typically using mechanical meters, into cylinders 

and tanks. The employee is trained and required to manually reset the meter to zero after each transaction 

and verify the meter is reset prior to initiating a subsequent transaction. This has been and remains an 

accepted practice for dispensing propane. This process is the industry standard for approximately 97 % of 

all propane used in the United States. See U.S. Department of Energy, Alternative Fuels Data Center 

afdc.energy.gov/fuels/propane_basics.html. 
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Unlike traditional motor-fuel, such as gasoline or diesel, customers cannot currently dispense propane into 

their vehicles. If NFPA 58 is amended to allow customers to dispense their own propane into their vehicles 

and the demand for propane as motor-fuel increases, the market will drive retailers to provide electronic 

customer-operated retail motor-fuel devices to meet the demand and customer expectations for efficient 

and expedient fueling transactions. At that time, the electronic customer-operated motor-fuel devices will 

certainly need to incorporate an automatic zero-set-back interlock. It is simply too early in the process to 

effectively force mechanical retail motor-fuel devices out of the market for such a small percentage of the 

retail propane market (approximately 3 %).

OWM Executive Summary for LPG-22.3 – S.2.5. Zero-Set-Back Interlock, Stationary 

and Vehicle Mounted Meters, Electronic., S.2.6. Zero-Set-Back Interlock, Vehicle 

Mounted Meters, Electronic., and S.2.67. Zero-Set-Back Interlock for Stationary SelfOperated Retail Motor-Fuel Devices.

OWM Recommendation: NIST OWM is not in support of this proposal to change S.2.5.2 requirements 

in the LPG Code and feel that this creates different requirements for retail motor fuel devices used for 

other products. Also, a proposal is needed for consideration of changes to timeout for LPG. 

• The submitters explained in their justification that only trained operators can dispense propane into a 

vehicle and that these propane retail motor fuel dispensers do not meet the requirements for Zero-Set 

Back Interlock for Stationary Retail Motor-Fuel Devices. As such, the submitters are proposing that 

since these are not customer operated dispensers, and that the dispensers are operated by trained staff, 

the requirements in S.2.5.2 Zero-Set-Back Interlock for Stationary Retail Motor Fuel Devices should 

be revised to only apply to Customer Operated Electronic Retail Motor Fuel Devices. The following 

are NIST OWM comments to this proposed change.

• If a dispenser is operating as a retail motor fuel device the current requirements for zero-set-back 

interlock apply whether or not it is operated by the customer or trained staff. 

• The purpose of the Zero-Set-back Interlock is to ensure that an automatic interlock prevents 

subsequent delivery until the indicating element is returned to zero. 

• With the changes proposed, any propane retail motor fuel device that is operated by trained staff 

could possibly not be returned to zero at the start the next transaction. 

• Propane retail motor fuel devices, that are not customer operated, would not be required to meet S. 

2.5.2. in the LPG Code. 

Table 3. Summary of Recommendations

LPG-22.3 S.2.5. Zero-Set-Back Interlock, Stationary and Vehicle Mounted Meters, Electronic., 

S.2.6. Zero-Set-Back Interlock, Vehicle Mounted Meters, Electronic., and S.2.67. Zero-Set-Back 

Interlock for Stationary Self-Operated Retail Motor-Fuel Devices.

V D W A I Notes* Comments

Submitter 

OWM

WWMA 
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Table 3. Summary of Recommendations

LPG-22.3 S.2.5. Zero-Set-Back Interlock, Stationary and Vehicle Mounted Meters, Electronic., 

S.2.6. Zero-Set-Back Interlock, Vehicle Mounted Meters, Electronic., and S.2.67. Zero-Set-Back 

Interlock for Stationary Self-Operated Retail Motor-Fuel Devices.

V D W A I Notes* Comments

SWMA 

NEWMA

No recommendation from this region was 

provided as no comments were heard 

from the body on this item during the 

2022 NEWMA Annual Meeting.

CWMA 

NCWM

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Liquefied Petroleum Gas and Anhydrous Ammonia Liquid-Measuring Devices Cod 

as follows: 

S.2.5. Zero-Set-Back Interlock. 

S.2.5.1. Zero-Set-Back Interlock, Electronic Stationary Meters (Other than Stationary Retail MotorFuel Dispensers) and Electronic Vehicle-Mounted Meters. − A device shall be constructed so that 

after an individual delivery or multiple deliveries at one location have been completed, an automatic 

interlock system shall engage to prevent a subsequent delivery until the indicating element and, if 

equipped, recording element have been returned to their zero positions.

[Nonretroactive as January 1, 2021] 

(Added 2019) 

(Amended 2021) 

S.2.5.2. Zero-Set-Back Interlock for Stationary Customer-Operated Electronic Retail Motor-Fuel 

Devices. – A device shall be constructed so that: 

(a) after a delivery cycle has been completed by moving the starting lever to any position that shuts 

off the device, an automatic interlock prevents a subsequent delivery until the indicating 
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elements and recording elements, if the device is equipped and activated to record, have been 

returned to their zero positions; 

(b) the discharge nozzle cannot be returned to its designed hanging position (that is, any position 

where the tip of the nozzle is placed in its designed receptacle and the lock can be inserted) 

until the starting lever is in its designed shut-off position and the zero-set-back interlock has 

been engaged; and 

(c) in a system with more than one dispenser supplied by a single pump, an effective automatic 

control valve in each dispenser prevents product from being delivered until the indicating 

elements on that dispenser are in a correct zero position.

[Nonretroactive as of January 1, 2017] 

(Added 2016)

NIST OWM Detailed Technical Analysis:

A similar proposal LPG-22.2, submitter U-Haul International, Inc. was withdrawn and both U-Haul 

International, Inc. and National Propane Gas Association collaborated to further develop LPG-22.3. 

Initially, the proposed changes, were made to an older version of the handbook. The current Item under 

Consideration has been edited and changes are being proposed to the current version of NIST HB 44. 

Per review of the discussion provided by the submitter, propane dispensed into a vehicle requires a trained 

operator to dispense the propane. From other proposals on the 2022 Interim Meeting report, it is NIST 

OWM understanding that some stationary propane dispensers have been retrofitted to dispense propane as 

fuel for vehicles. As such these dispensers are now retail motor fuel dispensers and must meet the 

requirements for these device in the LPG code.

The submitters explained in their justification that only trained operators can dispense propane into a vehicle 

and that these propane retail motor fuel dispensers do not meet the requirements for Zero-Set Back Interlock 

for Stationary Retail Motor-Fuel Devices. As such, the submitter is proposing that since these are not

customer operated dispensers, and that the dispensers are operated by trained staff, the requirements in 

S.2.5.2. Zero-Set-Back Interlock for Stationary Retail Motor Fuel Devices should be revised to only apply 

to Customer Operated Electronic Retail Motor Fuel Devices The following are NIST OWM comments to 

this proposed change.

• If a dispenser is operating as a retail motor fuel device the current requirements for zero-set-back 

interlock apply whether or not it is operated by the customer or trained staff. 

• The purpose of the Zero-Set-back Interlock is to ensure that an automatic interlock prevents subsequent 

delivery until the indicating element is returned to zero. 

• With the proposed changes, any propane retail motor fuel device that is operated by trained staff could 

possibly not be returned to zero at the start the next transaction.

 

• Retail motor fuel dispenser such as gasoline dispensers are required to meet these requirements in a 

self-serve (Customer operated) or full Service (Trained staff operated) locations.

• Propane retail motor fuel devices, that are not customer operated, would not be required to meet S. 

2.5.2. in the LPG Code. 
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• The title of the proposal will need to be updated with the current handbook paragraphs.

• In reference to requirements for a 5-minute timeout, the timeout was discussed by the conference in 

2021. During those discussions 2, 3 and 5 minutes were discussed. The conference adopted a 3- 

minute timeout which was added to NIST HB 44 in 2021. Although timeout was discussed in the 

submitters justification, the revised Item under Consideration did not include a proposal for a change 

to the timeout requirements for LPG. 

• NIST OWM is not in support of this proposal to change S.2.5.2 requirements in the LPG Code and feel 

that this creates different requirements for retail motor fuel devices used for other products. Also, a 

proposal is needed for consideration of changes to timeout for LPG. 

Summary of Discussions and Actions:

During the 2022 NCWM Interim Meeting, Mr. Bruce Swiecicki (National Propane Gas Association), 

working in collaboration with U-Haul International, requested the Committee replace the proposal in its 

2022 Interim Meeting agenda for this item with the following revised version: 

Amend Handbook 44, Liquefied Petroleum Gas and Anhydrous Ammonia Liquid-Measuring Devices Code 

as follows: 

S.2.6. Automatic Timeout. 

S.2.6.1. Electronic Stationary (Other than Stationary Retail Motor-Fuel Dispensers) and Electronic 

Vehicle-Mounted Meters. – For individual deliveries, if there is no product flow for three minutes the 

transaction must be completed before additional product flow is allowed. The three-minute timeout 

shall be a sealable feature on an indicator. 

[Nonretroactive as of January 1, 2021] 

(Added 2021) 

S.2.6.2. Zero-Set-Back Interlock, Electronic Vehicle Mounted Meters. - A device shall be so 

constructed that after an individual delivery or multiple deliveries at one location have been 

completed, an automatic interlock system shall engage to prevent a subsequent delivery until the 

indicating element and, if equipped, recording element have been returned to their zero position. For 

individual deliveries, if there is no product flow for a maximum of five minutes the transaction must 

be completed before additional product flow is allowed. The 5-minute timeout shall be a sealable 

feature on an indicator.

[Nonretroactive as of January 1, 2021] 

During Committee open hearings, Mr. Swiecicki acknowledge the proposal was based on an earlier version 

of NIST Handbook 44 and the paragraph numbering had changed. Consequently, the proposal needed 

modification to correspond to the 2022 version of the handbook. Mr. Swiecicki reported a two-minute time 

out was difficult to accomplish and suggested this be changed to five minutes.

During the Committee’s work session, members of the Committee reviewed the revised proposal, which 

includes updated language and paragraph numbering, however, members of the Committee concluded the 

proposal was still not fully developed. The Committee agreed to amend the proposal as requested by the 
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submitter. The Committee recommended the submitter of this item work with the submitter of LPG-22.2 

(U-Haul International) to harmonize the two proposals. 

Two officials supported Mr. Swiecicki’s comments and were also in favor of a five-minute time out. 

Ms. Diane Lee (NIST OWM) commented the proposal needed to be cleaned up to match the 2022 version 

of NIST Handbook 44. There was also a suggestion for the submitter to work with NIST OWM to further 

develop the proposal.

No comments were heard in opposition to the continued development of this item.

Following the 2022 Interim Meeting, the submitter of this item and Item LPG-22.2 collaborated on a joint 

proposal as requested and submitted it to the Committee in time that it could be added to the Committee’s 

agenda for the 2022 NCWM Annual Meeting. See the Item under Consideration for the new joint proposal.

Because the submitters combined the two items into one, the Committee was able to withdraw LPG 22.2. 

from its agenda. 

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Bruce Swiecicki (National Propane Gas Association): This addresses two subjects: has to do with zero 

setback, but were breaking out vehicle meters. In some situations with a bobtail where there may be several 

tanks not close to one another and the operator has to carry the long hose. They have to walk from tank to 

tank. They want more time (5 minute timer). He supports this but wants to break out the systems that aren’t 

used full time for Retail motor fuel.

Mr. Dwight Farr (U-Haul Program Manager): they are in support of the NPGA proposal.

Mrs. Tina Butcher (NIST OWM): Look at the previous verbiage. The Conference did vote on changes 

with regard to zero setback and time out in 2021. The paragraph number is different than the 2020 version. 

The WWMA S&T Committee recommends based on testimony heard in open hearings and input from the 

NIST advisors during the work session that this item be assigned a Developing status. The Committee also 

recommends that the submitters of LPG-22.2 and LPG-22.3 combine their efforts to develop one of the 

items with consideration to the 2022 version of NIST HB 44.

Southern Weights and Measures Association

At 2021 Annual SWMA Meeting Open Hearing, Mr. Steve Benjamin (North Carolina) supported this item. 

This Committee recommends this item move forward as a Voting item.

Northeastern Weights and Measures Association

During the 2021 Interim NEWMA S&T open hearings, no comments were heard on this item. 
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The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status.

During the 2022 Annual Meeting Open Hearing no comments were received on this item and NEWMA 

made no recommendation to the NCWM.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing, the Committee heard no comments from the floor. 

Committee received updated proposal to S.2.5. and S.2.6 from Mr. Bruce Swieciki (National Propane Gas 

Association) because technology won’t be available 2022 per manufacturers.

CWMA S&T Committee recommends item move forward as a Developing item.

During the CWMA’s 2022 Annual Meeting, the CWMA’s Committee considered the following comments: 

Mr. Konrad Pilatowicz (U-Haul International) (comments received via email prior to the meeting): This 

proposal was developed by the National Propane Gas Association’s Technology, Standards and Safety 

Committee, a volunteer organization comprised of 2500+ members, including propane retail marketers and 

others providing products or services to the propane industry. 

Addressing proposed S.2.5.2, motor fuel, within the context of NFPA 58, refers to any container that has 

the potential to provide propane to fuel an engine. This can include a multitude of DOT cylinders and 

ASME containers that are not for the propulsion of an automobile. Current mechanical meter technology 

utilized in a standard propane dispenser for the filling of portable containers, such as those utilized in NFPA 

58 for motor fuel applications or those that do power automobiles, are not capable of being equipped with 

a zero-set-back interlock and the technology will not be potentially available until 2022, per meter 

manufacturers. 

NFPA 58 does not currently explicitly allow the public to refuel its automobiles. All automobiles or other 

containers must be filled by a specially trained employee. A proposed change has been introduced for 

consideration in the 2023 20 edition of NFPA 58 that would permit public refueling of automobiles as long 

as the dispensing system meets specific safety requirements, including a specialized nozzle, and is furnished 

with visible instructions. Upon the acceptance of this new public refueling allowance the propane industry 

agrees that Zero-Setback-interlocks are needed. These public self-service automotive dispensing systems 

will be listed to Underwriters Laboratories Standard 495 and will be dedicated to the filling of motor 

vehicles. 

In view of the above information, existing dispenser systems with mechanical registers that may only be 

utilized by qualified trained employees should be permitted to continue operations with the existing meter 

technology and should not be required to include Zero-Set-Back Interlocks. This should include when the 

dispenser is removed from one location and installed in another, as long as the original meter remains 

functional. Existing cabinetry and controls utilized in a standard dispenser cabinet generally include nondigital meters and no electronic controls with the exception of a single switch that operates the pump. These 

simplistic designs are still effective and should not be prohibited from use in future (new) installations in 

which the transfer process is attended by trained personnel. 

Limiting the scope of this section will allow attended dispenser operations which are primarily utilized for 

filling of portable containers to remain consistent in design and construction. Current use of this technology 
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has not resulted in any known impact to the consumer or over- charge situations. The term “customeroperated” is used in several other locations in Handbook 44.

Mr. Michael Keilty (Endress+Hauser, NTEP Measuring Sector) – This is a new item that the NTEP 

Measuring Sector has not reviewed and would like to discuss at their September 2022 meeting.

Based upon these comments, the CWMA recommended this item as a Voting item on the NCWM agenda.

MFM – MASS FLOW METERS

MFM-15.1 D N.3. Test Drafts.

Previously MFM-2

(Note: In 2019 this item was combined with Block 1 “Terminology For Testing Standards” and other items 

that addressed terminology for standards and the use of “master meters.” Based on comments heard during 

the 2021 Annual Meeting, the S&T Committee recommended that all items that were combined with Block 

1 “Terminology For Testing Standards” that originally appeared as a separate item or a separate block of 

items on the S&T agenda prior to 2019, be removed from Block 1 “Terminology For Testing Standards”

and appear as originally presented.

Item MFM-15.1 was removed from Block 1 “Terminology For Testing Standards” and now appears as a 

separate item on the 2022 Interim Meeting agenda.)

Source: Endress + Hauser Flowtec AG USA

Purpose and Justification:

Amend Handbook 44 to allow field reference standard meters to be used to test and place into service 

dispensers and delivery system flow meters. This item has been assigned to the submitter for further 

development. For more information or to provide comment, please contact:

Mr. Michael Keilty

Endress + Hauser Flowtec AG USA

(970) 586-2122, michael.keilty@us.endress.com

The use of transfer standards is recognized in Code sections 3.34 Cryogenic Liquid-Measuring Devices 

Code and 3.38 Carbon Dioxide Liquid-Measuring Devices Code and 3.39 Hydrogen Gas-Measuring 

Devices – Tentative Code. Transfer standard is only defined for testing cryogenic liquid measuring devices. 

It has been pointed out that the term transfer standard is not correct and that field reference standard meters 

may be more appropriate. See new the Item under Consideration, updated on September 8, 2017.

Field evaluation of LPG meters and CNG dispensers and LNG dispensers is very difficult using volumetric 

and gravimetric field standards and methods. The tolerances for these applications are such that using field 

reference standard meters are more efficient and safer. With CNG and LNG and LPG applications, the field 

reference standard meters are placed in-line with the delivery system as it is used to fill tanks and vehicles. 

The use of field reference standard meters eliminates return to storage issues. The use of field reference 

standard meters is easier and faster compared to the use of traditional field standards. The cost of using 

field reference standard meters and transporting them is much less than the cost of traditional field provers 

and standards.
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Recognition in Handbook 44 will enable States to allow field reference standard meters to place systems 

into service and for field enforcement.

Volumetric field provers and gravimetric field proving are susceptible to environmental influences. The 

State of Colorado uses a field reference standard meter to test propane delivery truck meters. The State of 

Nebraska has used a field reference standard meter to test agricultural chemical meters. Other States have 

asked that there be recognition in HB 44 in order for their State to allow the use of field reference standard 

meters.

In some applications, field reference standard meters are not more accurate than the meters used in the 

application. For that reason, longer test drafts and possibly more tests may need to be run.

The State of California is purported to have conducted a short study of field reference standard meters in 

the past. The conclusion did not lead to wide adoption of the practice. 

Section 3.37 Mass Flow Meters user requirement U.R.3.8. Return of Product to Storage, Retail Compressed 

Natural Gas Dispensers requires that the natural gas which is delivered into the test container must be 

returned to storage. This is difficult and most often not complied with when the test vessel contents are 

released to atmosphere. States often have difficulties in remote locations finding suitable field reference 

equipment.

OWM Executive Summary for MFM-15.1 – N.3. Test Drafts.

OWM Recommendation OWM believes that the purpose for this item, as specified by the submitter, 

is better addressed from a technical standpoint in Item Block 8.

• State and industry have a need to use various types of field test standards to evaluate commercial 

devices installed in the marketplace. NIST OWM recognizes the need to use various standards to 

test commercial devices and support the use of these standards when test data supports its use.

• The NIST OWM is also supporting the use of field test standards through the purchase of several 

meters and the collection of data throughout the U.S.

• The purpose statement for Item MFM-15.1 (Mass Flow Meters Code) indicates the goal of this item 

is:

o “to amend Handbook 44 to allow field reference standard meters to be used to test and place 

into service dispensers and delivery system flow meters.”

• The proposed changes in Items MFM-15.1 suggest changes to the test draft criteria for devices 

covered under this code, which is not necessary to allow field reference standard meters to be used 

to test and place into service dispensers and delivery system flow meters.

• Amongst the concerns raised to the S&T Committee over the proposed changes for MFM-15.1, is 

the inability for an inspector or service company to test devices under their conditions of use and as 

required elsewhere in the MFM code.
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OWM Executive Summary for MFM-15.1 – N.3. Test Drafts.

o Specifically, with the proposed addition of a paragraph N.3.2. Field Reference Standard Meter 

Test., no information or data has been provided to justify that:

 a different test draft size than that specified in N.3.1. or the current Mass Flow Meter, NIST 

HB 44 paragraph N.3 Test Draft is necessary in order to use a “Field Reference Standard 

Meter.” 

 the current requirements for test draft “one test draft at the maximum flow rate of the 

installation and one test draft at the minimum flow rate” is appropriate for use when testing 

with a meter or volume prover.

o This proposal creates two test draft paragraphs in NIST HB 44. It retains the existing criteria for 

the test draft and adds a proposal for a second test draft paragraph that states “the test draft shall 

be equal to or greater than the amount delivered in one minute” 

 It has been observed when testing CNG that some draft will take far less time than one 

minute. If the proposed test draft paragraph is added the test draft will not be achievable 

and as stated unable to test under conditions of use.

 Since this proposal adds another test draft paragraph with the existing paragraph for test 

draft it also creates confusion as to what paragraph the inspector should apply.

As such, given the long debate over multiple iterations of the proposals, OWM proposes that 

since the purpose of the proposal is to allow field reference standard meters to be used to test

and place into service dispensers and delivery system, and the responsibility for allowance of 

these field test standards are already addressed in the NIST Handbook 44 Fundamental 

Considerations and Item Block 8 clarifies these responsibilities, that Consideration be given to 

the proposal in Item Block 8 which clearly states the responsibility for allowance of field 

standards along with a new proposal to add a general code requirement. 

• Note that Block 8 items clarify what has long been recognized in NIST HB 44 concerning the 

responsibility for acceptance of a standard making changes to specific codes such as those references 

in MFM-15.1 and is better addressed in Block 8. 

• Additionally, the Committee is aware that a new Form 15 has been submitted by Seraphin for the 

2023 cycle proposing a new General Code paragraph which clearly references the Director’s authority 

as outlined in the Fundamental Considerations.

o This not only avoids the need to specifically reference individual test methods in each specific 

code, it avoids the potential of implying that test methods not specifically referenced in a code 

would not be appropriate.

• G-N.3. Test Methods. – Permissible test methods for verifying compliance of weighing and 

measuring systems with the provisions of the General Code and Specific Codes include, but are 

not limited to, test methods and apparatus that have been approved by the State Director of 

weights and measures as outlined in Appendix A - Fundamental Considerations, Section 3. 

Testing Apparatus. 
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Table 3. Summary of Recommendations

MFM-15.1 N.3. Test Drafts

V D W A I Notes* Comments

Submitter 

OWM

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM

Letters of Support Letters of Opposition Notes

Industry

• Letter from 

Endress+Hauser (10-

07-2021)

• Endress+Hauser Slides 

(01-11-2022)

• Endress+Hauser Letter 

to CWMA (05-12-

2022)

• Comments from 

Seraphin (09-27-2016)

• Comments from 

Seraphin (06-23-2017)

• Comments from 

Seraphin (07-02-2018)

• Comments from 

Seraphin Test Measure 

Co. (06-17-2022)

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Mass Flow Meters Code as follows: 

N.3. Test Drafts. 

N.3.1 Minimum Test - The minimum test shall be one test draft at the maximum flow rate of the 

installation and one test draft at the minimum flow rate. More tests may be performed at these or 

other flow rates. (See T.3. Repeatability.)

(Amended 1982 and 20XX)) 

N.3.2. Field Reference Standard Meter Test. – The minimum quantity for any test draft shall 

be equal to or greater than the amount delivered in one minute at the flow rate being tested.

(Added 20XX)
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NIST OWM Detailed Technical Analysis:

• Although this item has been on the agenda for a number of years, this item was group in a block of 

other similar items then removed from the block and placed back on the NCWM agenda as it originally 

appeared on the agenda. 

• NIST OWM is working with States using Coriolis meters to collect data on the use of these meters as 

standards to test liquid measuring devices. This data will be shared with all regulatory officials to assist 

them with their approval of meters as standards.

• This purpose indicates its intent is to permit the use of field reference standard meters in field testing 

of commercial measuring systems.

• It is not necessary to reference “field reference standards” in a specific NIST HB 44 code in order to 

permit their use.

• Criteria for assessing the use of a given type of test standard are outlined in NIST HB 44 Appendix A 

Fundamental Considerations.

• The decision on whether or not to accept a particular test method for use in testing commercial weighing 

and measuring equipment ultimately rests with the regulatory authority.

• NIST OWM and Seraphin developed Block 8 items (GEN-19.1 and OTH-22.1) on the 2022 Annual 

Meeting Report to help clarify and provide additional information on field standard traceability and 

specifications, and the regulatory authority’s responsibility for approval of field standards.

• Specifically, with regard to the proposed addition of a paragraph N.3.2. Field Reference Standard Meter 

Test, no information or data has been provided to justify that:

 a different test draft size than that specified in N.3.1. or the current Mass Flow Meter, NIST HB 44 

paragraph N.3 Test Draft is necessary in order to use a “Field Reference Standard Meter.” 

 The current requirements for test draft “one test draft at the maximum flow rate of the installation 

and one test draft at the minimum flow rate” is appropriate is for use when testing with a meter or 

volume prover.

• This proposal creates two test draft paragraphs in NIST HB 44. It retains the existing criteria for the 

test draft and adds a proposal for a second test draft paragraph that states “the test draft shall be equal 

to or greater than the amount delivered in one minute”. 

• It has been observed when testing CNG that some draft will take far less time than one minute. If 

the proposed test draft paragraph is added the test draft will not be achievable.

• Since this proposal adds another test draft paragraph with the existing paragraph for test draft it 

also creates confusion as to what paragraph the inspector should apply.

As such, given the long debate over multiple iterations of the proposals, OWM proposes that since the 

purpose of the proposal is to allow field reference standard meters to be used to test and place into service 

dispensers and delivery system, and the responsibility for allowance of these field test standards are already 

addressed in the NIST Handbook 44 Fundamental Considerations and Item Block 8 clarifies these 

responsibilities, that Consideration be given to the proposal in Item Block 8 which clearly states the 

responsibility for allowance of field standards along with a new proposal to add a general code requirement. 
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Summary of Discussions and Actions:

In the fall of 2016, Mr. Keilty provided an update to the Item under Consideration. That update appears in 

the agenda. The previous proposed Item under Consideration was as follows:

N.3. Test Drafts. – 

N.3.1 Minimum Test - Test drafts should be equal to at least the amount delivered by the device 

in one minute at its normal discharge rate. 

(Amended 1982)

N.3.2. Transfer Standard Test. – When comparing a meter with a calibrated transfer 

standard, the test draft shall be equal to at least the amount delivered by the device in 2 

minutes at its maximum discharge rate. 

The submitter recommends that NIST update EPO 28 for CNG dispensers and EPO 26 for LPG Liquid 

Measuring Systems to include transfer standard meter tests. NIST Publication R 105-4 should also be 

revised to specifically address the transfer standard meter and the requirements for use.

The S&T Committee might also consider amending Sections 3.30 Liquid-Measuring Devices Code and 

3.31 Vehicle-Tank Meters Code to allow transfer standard meters.

The Committee received written comments on all items in Block 4 and Block 5, as well as LPG-4 and 

MFM-2 emphasizing the need for there to be more study and discussion of the issues to assess the 

ramifications of all the proposed changes. The Committee also received written comments from the SMA 

that it looks forward to further information on these items and stating that it is important to be consistent in 

our use of terms across multiple sections of Handbook 44. The Committee agreed to carryover this group 

of items on its 2019 agenda to allow for further discussion and development of these proposals.

At the 2019 NCWM Interim Meeting, the S&T Committee decided to combine the items on the agenda 

dealing with the issue of transfer standard (including items already combined into blocks) into one block. 

Block 1 (New) of the Interim Meeting report now includes GEN-3, Block 1 (original items from the 2019 

interim agenda that appeared under Block 1), Block 2, LPG-3, and MFM-5, which were all separate items 

and blocks of items on the S&T Committee’s 2019 Interim Meeting agenda (NCWM Publication 15). 

Agenda items GEN-3, Block 1, Block 2, LPG-3, and MFM-5 are listed separately on the Interim agenda 

with a note added beneath each individual item referring the reader to the New B1 items. All items under 

this New B1 have retained the same numbering system for ease in referring to the appendix for discussion 

on each item.

At the 2019 NCWM Annual Meeting, Mr. Brett Gurney (NCWM Chairman) commented regarding the 

formation of a Task Group assigned to further develop this block proposal. The TG is charged with 

providing definitions for various types of standards (transfer, field, reference, etc.) as well as the criteria to 

be met by these types of standards. The completion date given to the TG is July 2021. The Committee 

agreed to the Assigned status for this block of items and looks forward to hearing updates from the TG. 

The Chair of the Task Group was:

Mr. Jason Glass

Kentucky Department of Agriculture

(502) 573-0282, jason.glass@ky.gov
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At the 2020 NCWM Interim Meeting Field Standard TG Chair Glass reported that the Task Group met 

prior to the Interim Meeting and has begun discussion of the items under Block 1. Mr. Glass stated that biweekly teleconference meetings were scheduled and that the group was optimistic but had significant work 

to accomplish. 

Mr. Russ Vires (SMA) supports the Scale item, SCL 18.1; in this block, Mr. Dimitri Karimov (Meter 

Manufacturers Association) supports the Task Group activities, Mrs. Tina Butcher was encouraged with 

the progress on terminology and provided an update on the Mass Flow Meter testing reporting that field 

testing was conducted October 28 to November 1, 2019 and that State and Industry participation included 

Colorado, Florida, Oregon, Emerson, and Tulsa Gas Technology. 

Mr. Kurt Floren (Los Angeles County, California) raised concerns with GEN-19.1. regarding the definition 

of “Standard, Field” and its reference to “stable” standards and how long a standard is expected to be stable, 

which is typically 1-year, for which he believes should be longer. Mr. Floren also questioned the statement 

in the definition “tested over a range of environmental and operational conditions that the measuring devices 

is used...”. Mr. Floren noted that he was unsure if all laboratories will have the capabilities to test over this 

wide range of conditions. Mr. Floren also expressed concerns with the definition “Standard, Transfer” 

citing that this standard may not meet the fundamental considerations requirement for standards over a long 

period of time or wide range of environmental conditions. 

Mr. Steve Harrington (Oregon) echoed Mr. Floren’s comments. Field Standard TG Chair Glass responded 

that these are concerns of the TG and these issues will be discussed and considered as the TG develops 

these items. 

During the Committee’s work session, the Committee agreed that this item should remain an Assigned 

item.

At the 2021 NCWM Interim Meeting, the NCWM Field Standard TG Chair, Mr. Jason Glass (Kentucky) 

provided an update on the Task Group activities. Mr. Glass reported that the field standard Task Group is 

following the activities of the NIST Master Meter Project and that the Task Group reviewed API 

specifications for use of master meters as a standard and a test protocol that will be used to ensure uniformity 

in collecting data on master meters used as field standards. Mr. Glass also reported that the TG does not 

have a recommendation for this item. Mr. Glass also reported that he would be stepping down as the TG 

Chair. Mr. Mike Keilty (Endress+Hauser AG) thanked Chair Glass and the TG for their work and requested 

that Block 1, LPG-15.1, N.3. and Block 1 MFM-15.1, N.3 be removed from Block 1 items and to allow 

those items to move forward separate from the other Block 1 Items. Mr. Keilty stated that similar language 

was added to the Hydrogen code and that the proposed language in LPG-15.1 N.3. and MFM-15.1, N.3 will 

allow for the recognition of master meters as field standards. Mr. Henry Oppermann (W&M Consulting), 

stated that data is needed to ensure that master meters can be used over a range of conditions. Mr. Bob 

Murnane (Seraphin) stated that jurisdictions have the ability to use meters and that Block 1 LPG-15.1, N.3 

and Block 1 MM-15.1, N.3 should remain in Block 1 until data is available to support the use of master 

meters as a standard. Mr. Keilty mentioned that there has been useful dialog regarding master meters in 

the TG, but that he is concerned that the TG is not close to deciding and he expressed concerns with the 

TG’s focus on the NIST Master Meter Project. Mrs. Tina Butcher (NIST OWM) provided an update on 

the NIST Master Meter Project and noted that States have the regulatory powers to accept or reject a 

standard. She also mentioned that NIST is working with States to collect data needed to assess master 

meters and preliminary testing was conducted and data was collected on CNG at Tulsa Gas Technology’s 

facility in fall 2019. Ms. Diane Lee (NIST OWM) noted that NIST OWM feels that it is premature to add 

more language to the NIST Handbook 44 on master meters without data to support its use.
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During the Committee’s work session, the Committee agreed to keeps all items in Block 1 and that this 

item should remain with an Assigned status.

At the 2021 NCWM Annual Meeting, Mr. Glass reported that he would be stepping down as the Field 

Standard TG Chair. The Committee heard updates from members of the Task Group during open hearings. 

Mr. Michael Keilty noted that two of the items had been on the agenda since 2015 and requested that they 

be removed from the block and recommended recognizing the use of master meters. Other comments were 

to keep the items together until data is analyzed from the NIST Field Reference Standard Work Group to 

support the use of master meters but that if some items were removed from the block, all items should be 

removed from the block. Based on comments heard during the 2021 Annual Meeting, the S&T Committee 

recommended that all items that were included in Block 1 “Terminology For Testing Standards” that 

originally appeared as a separate item or a separate block of items on the S&T agenda in and prior to 2019, 

be removed from Block 1 “Terminology For Testing Standards” and appear as originally presented. 

During the 2021 Committee work session the Committee recognized that the Task Group has accomplished 

all it is able to at this point and is recommending the Task Group be disbanded and will make said 

recommendation to the NCWM Chairman. The Committee agreed to break all items in Block 1 into 

individual items and designate them all as Developing. The Committee thanks the Task Group and its 

members for their work. 

At the 2022 NCWM Interim Meeting the Item under Consideration presented at this meeting is provided 

below. 

N.3. Test Drafts. 

N.3.1 Minimum Test - The minimum test shall be one test draft at the maximum flow rate of the 

installation and one test draft at the minimum flow rate. More tests may be performed at these or other 

flow rates. (See T.3. Repeatability.)

(Amended 1982 and 20XX)) 

N.3.2. Field Reference Standard Meter Test. – The minimum quantity for any test draft shall be 

equal to or greater than the amount delivered in one minute at the flow rate being tested.

(Added 20XX)

Mr. Keilty shared a presentation on field standard meters during open hearings relevant to both MFM 15.1 

and LPG 15.1. The intent of the presentation was to describe initial and ongoing calibration traceability, 

compare OIML tolerances vs NIST Handbook 44, describe the benefits and show example. An abbreviated 

copy of the presentation is available on the NCWM website in the interim meeting documents archive. Mr. 

Keilty commented that he believes MFM 15.1 and LPG 15.1 are fully developed and should receive voting 

status for the annual meeting. He has updated the proposal to exclude the term “reference” from “field 

reference standard meter test”, as shown above. He requests that the Committee provide specific guidance 

if a Developing status is assigned. A comment from industry (Mr. Bob Murnane (Seraphin)) stated that 

N.3.2 in the proposal conflicts with the current code which states normal test drafts must be at least one 

minute at the maximum discharge flow rate of installation conditions. The current wording allows for a 

test to be conducted at any flow rate for one minute. There was concern from a regulator (Charles 

Stutesman, Kansas) echoing these concerns. Ms. Diane Lee (NIST OWM) requested that more data be 

made available so that NIST is able to compare worldwide data against test data compiled within the U.S. 

by NIST. Mr. Mahesh Albuquerque (Colorado) expressed support for this item to receive Voting status. 

Mr. Marc Butler (Emerson Micro Motion) expressed confusion at the two notes, thinking that perhaps they 
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conflicted with each other; are they both needed or are they independent? Mrs. Tina Butcher (NIST OWM) 

expressed that she recognizes the use and importance of master meters, but is concerned with the purpose 

of this item. Mrs. Butcher suggested that the statement for use be reworked as test draft criteria is so critical. 

Mrs. Butcher recommended and offered NIST OWM assistance on this item.

During the S&T Committee work session, the Committee recognized the submitters desire that a Voting 

status be recommended but determined that there were too many concerns and confusion expressed. The 

Committee recommends that the submitter develop the item further by aligning language to existing 

language in Handbook 44, clarifying the purpose to help avoid confusion of the new code on new 

equipment, and reaching out to NIST OWM or other industry or regulatory officials for feedback.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Michael Keilty (Endress + Hauser): companion item to LPG-15.1. This is enabling language. Wants 

this to be a Voting item in 2022. 

Mr. Bob Murnane (Seraphin): does not recognize the verbiage, needs a definition - see previous comments 

(referencing LPG-15.1, field reference standard meter).

Ms. Diane Lee (NIST OWM): agreed with Mr. Keilty about companion item. Clarification to both items: 

MFM-15.1 - in HB the purpose statement is not there. In Amendment A there is already criteria there. 

Needed justification for language in N.3.2 - standard meter test - the min. quant. for any test draft shall be 

equal to or greater than am. delivered in 1 min. of the amount being tested. In CNG there is a 1/3 test being 

conducted. It wouldn’t even take a minute to deliver. The question was: how do you come up with 1 min. 

and this would not be appropriate for all master meters.

Mr. Keilty addressing Ms. Lee in 2016 there was supposed to be a vote. NIST tech. adviser brought this up. 

There was a revision to the time to be extended. CNG is completely separate, EPO does say 1/3 but that 

was when CNG tanks were small (delivered at lower flow rate and shorter time). Mr. Wagner can verify. 

He made it 1 min. because N.3.1 says one test draft at the max. flow rate and one at the min. flow rate of 

installation.

The WWMA S&T Committee recommends the status remain Developmental. The Committee recommends 

that consideration be made that this item be included in Block 5, as they refer to the same terminology in 

HB 44. A letter was submitted to the Committee by Mr. Keilty and will be posted to the NCWM website. 

NIST OWM also submitted analysis on this item which can be found at the following link on the NCWM 

website: https://www.ncwm.com/annual-archive.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, Mr. Henry Oppermann (Seraphin) stated that this creates 

a conflict with the Mass Flow Meter code regarding the minimum test. He also stated that he believes this 

item is unnecessary, because Field Standard Tests are already specified. 
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Mr. Keilty (Endress+Hauser), the submitter, suggested an editorial revision to striking the words 

“Reference” and “Meter” from “N.3.2. Field Reference Standard Meter Test.” in this proposal and moving 

it forward as a Voting Item. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Michael Keilty (Endress + Hauser Flowtec) commented and recommended Voting status with the 

changes below.

N.3.2. Field Reference Standard Meter Test. – The minimum quantity for any test draft shall be 

equal to or greater than the amount delivered in one minute at the flow rate being tested.

(Added 20XX)

Mr. Rick Harshman (NIST OWM) commented and discussions were had regarding states meeting the 

requirement of flow time that may be less than the one minute flow in N.3.2. 

Mr. Keilty responded that new equipment is in place and will meet the requirement in N.3.2.

Mr. Henry Opperman (Weights and Measures Consulting) commented that some NTEP certs may have 

been issued that would not meet the N.3.2 in this proposal.

The Committee would like to have clarification on questions regarding the current NTEP certs and test draft 

sizes that are currently being used. 

The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status. 

During the 2022 Annual Meeting open hearings Mr. Bob Murnane (Seraphin) commented that he does not 

believe this item is fully developed and recommended that the Committee consider withdrawing the item. 

Mr. Murnane read from submitted comments. Of note, Mr. Murnane indicated that under the Fundamental 

Considerations in HB 44, the State Director has the authority to evaluate standards for use in certifying 

meters and the fear is that if this proposal goes through, the handbook would have to be changed for each 

new technology. Mr. Murnane explained that several states have already evaluated meters to use as 

standards and determined them to be accurate to use. If this proposal is adopted, Mr. Murnane believes that 

it would take powers away from State Directors to evaluate and use these standards. Mrs. Tina Butcher 

(NIST OWM) commented that the concept of master and reference meter is to use the meter as a standard 

in place of provers. The authority to use them rests with the State Director, however, there needs to be a 

method to ensure accuracy. Mrs. Butcher mentioned several alternatives as outlined in the submitted NIST 

analysis.

During open hearings, comments were heard from the floor regarding this item and LPG-15.1 at the same 

time.

After hearing comments from the floor, the Committee does not believe the item is fully developed, even 

though the item has been on the agenda for several years. The Committee recommended that the item be 

withdrawn.
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Central Weights and Measures Association 

During the 2021 Interim Meeting open hearings the Committee heard comments from the floor. Mr. 

Michael Keilty (Endress+Hauser Flow) asked that the item be moved to Voting and if not, asks for 

suggestions from the Committee on how to improve item. Mr. Henry Opperman (Weights and Measures 

Consultants) does not support the item. Says it does not explain mass flow meter as a standard and where 

is the data that supports this item. Mrs. Tina Butcher (NIST OWM) agreed with comments from Mr. 

Opperman. Mr. Charles Stutesman (Kansas) agreed with Mrs. Butcher but understands the submitting of 

this proposal and should be moved as a Voting item.

CWMA S&T Committee recommends this item moving forward as a Voting item.

At the 2022 Annual Meeting Open Hearings, Mr. Keilty presented calibration data at the 2022 NCWM 

Interim Meeting. No recommendations from NCWM have been released. Recommended a minor change 

that re-includes the word “meters” because it was confusing how to apply testing requirements. Both items 

explain the amount of test drafts that differ from other volume standards. Field standard meter provides 

flexibility for use across many different products and densities. Field Standards are tested against OIML 

and API standards using gravimetric methods that are NIST traceable. Accuracy and repeatability are long 

term, it is a maintenance free system with no moving parts. These systems save time and space, contain 

embedded diagnostics, are easy to use, and easy to maintain. It is easy to train the operator of these systems. 

NMi has issued a test report on this system. Various setups can be mounted to a rack and easily transported. 

SWMA and CWMA recommended this item move forward as voting item in the 2021 Interim meeting. 

Recommending placing as voting today and move forward for a vote this week.

Mr. Jan Konijnenburg (NIST OWM) - State and industry have a need to use various types of field test 

standards to evaluate commercial devices installed in the marketplace. NIST OWM recognizes the need to 

use various standards to test commercial devices and support the use of these standards when test data 

supports its use.

The NIST OWM is also supporting the use of field test standards through the purchase of several meters 

and the collection of data throughout the U.S.

The purpose statement for Item MFM-15.1 (Mass Flow Meters Code) indicates the goal of this item is:

“to amend Handbook 44 to allow field reference standard meters to be used to test and place into service 

dispensers and delivery system flow meters.”

The proposed changes in Items MFM-15.1 suggest changes to the test draft criteria for devices covered 

under this code, which is not necessary to allow field reference standard meters to be used to test and place 

into service dispensers and delivery system flow meters.

Amongst the concerns raised to the S&T Committee over the proposed changes for MFM-15.1, is the 

inability for an inspector or service company to test devices under their conditions of use and as required 

elsewhere in the MFM code.

As such, given the long debate over multiple iterations of the proposals, OWM proposes that since the 

purpose of the proposal is to allow field reference standard meters to be used to test and place into service 

dispensers and delivery system, and the responsibility for allowance of these field test standards are already 

addressed in the NIST Handbook 44 Fundamental Considerations and Item Block 8 clarifies these 

responsibilities, that Consideration be given to the proposal in Item Block 8 which clearly states the 
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responsibility for allowance of field standards along with a new proposal to add a general code requirement. 

(See Item Block 8 of the NIST OWM Analysis for the S&T Annual Meeting.)

OWM Recommendation: OWM recommends that this item be withdrawn, and that consideration be given 

to Item Block 8.

Mr. Mike Johnson (Nebraska) supports this item and agrees with Mr. Keilty. Nebraska has had great 

success over the last 18 years using this method. Nebraska has over 300 mass flow meters and gravimetric 

testing isn’t practical.

Mr. Bob Murnane (Seraphin) stated purpose on these proposals to amend Handbook 44 and to allow field 

standards meters to be used to test and place into service dispensers and delivery system flow meters. The 

current language adding N.3.2., has nothing to do with the purpose statement nor does have any effect at 

all on whether meters can be accepted or used as field standards.

Handbook 44 under fundamental considerations already allows for the use of field standards and /or 

equipment, as approved by the Director. There are already numerous meters in the field being used as 

standards that have been approved by State Directors under these fundamental considerations.

Note: Seraphin has a proposal, item OTH-22-1 that supports the Directors authority.

What is the reason and justification for N.3.2 when we already have a test draft size in N.3.1?

What data and analysis has been provided regarding the uncertainties associated with the field standard 

meters and the sizes of the drafts proposed in N.3.2.?

The proposal MFM-15.1., N.3.2 would impose constraints on the capability of the W&M officials to test 

mass flow meters.

Under the current paragraph N.3., W&M officials can conduct tests at any flow rate for any quantity that is 

equal to or greater than minimum measured quantity (MMQ) specified by the manufacture of the meter.

Under the proposed N.3.2., the minimum size of the test drafts must be greater than or equal to the quantity 

delivered in one minute at the flow rate at which the test is being conducted. Depending upon the 

measurement application and the test equipment available, this could substantially increase the size of the 

required test drafts for almost all flow rates for mass flow meters.

Example: Recently there was CNG testing performed in Colorado. The test drafts were for 1/3 of the 

capacity of the test cylinder (as specified in the EPO) and it took less than one minute to complete. In this 

case the proposed change to the size of the test draft on MFM15.1. would have prevented Weights & 

Measures officials from conducting the tests.

Weights and Measures officials should be able to test mass flow meters using any test draft size, equal to 

or greater than the MMQ over the range of flow rates. I did not do an extensive review, but I did find six 

NTEP Certificates of Conformance that would not be able to be tested using the proposed MFM-15.1., 

N.3.2. What happens to them?

If the proposal were adopted with its current purpose statement it could be interpreted that every meter is 

acceptable for use as a field standard. How do you know which meters are acceptable for use as a field 

standard and which ones are not? For example, if a meter is brought into the United States from another 
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country, can it be used as a field standard. This proposal will cause confusion for both Weights and Measure 

officials and testing companies.

Additional Notes:

NIST and Seraphin requested Mr. Keilty’s participation in a meeting on these items and he declined. There 

has been a total of six changes to the wording on these items since they were introduced. Again, I would 

like to remind the Committee that States are already using meters as field standards and this is permitted 

by the existing fundamental considerations. There is no need for these proposals. Seraphin Test Measures 

opposes items LPG-15.1. and MFM-15.1 and asks the Committee to withdraw this item from consideration.

Comment: Years on an agenda are not part of criteria for deciding if an item should be made a Voting item.

Mr. Charlie Stutesman (Kansas) - Regarding Fundamental Considerations: States already have the ability 

to decide what’s allowed. It already falls within The Director’s authority, but we have other existing codes 

in HB 44 which reference transfer standards and specifically allowing their use for testing particular 

devices. The NIST EPOs are still in draft status and are a resource tool only. Flow rate will be more 

important going forward as gravimetric testing becomes more prevalent. Recommends sending to Voting 

status. Does this only apply to mass flow meters as the standard? NIST stated they are using Coriolis 

meters. But the decision to use non-mass flow meters as the field standard rests with The Director. This 

will apply to any meter technology, not just mass flow meters.

Mr. Michael Keilty (Endress+Hauser) - Other codes in HB 44 contain advice on specific test drafts when 

using transfer standards. These proposals give test draft advice to handle slow flow devices. The EPO for 

CNG testing uses small containers but the EPO can be changed.

Mr. Ivan Hankins (Iowa) has witnessed these tests using these transfer standards at multiple flow rates and 

drafts. It took much less time. This technology will allow jurisdictions to test at a quicker pace, using less 

staff. Supports this proposal.

Mr. Bob Murnane (Seraphin) questioned if the draft size is merely a suggestion.

The CWMA S&T Committee recommends this moves forward as a Voting item.

MFM-22.1 V Table T.2. Accuracy Classes and Tolerances for Mass Flow Meters.

Source: NIST Office of Weights and Measures

Purpose and Justification:

Currently Handbook 44, Section 3.37 Mass Flow Meters Code paragraph A.2. Vapor (Gases) recognizes 

measurements of hydrocarbon gases, but the code is silent to this product application in Table T.2 Accuracy 

Classes and Tolerances for Mass Flow Meters. This proposed modification to Table T.2 clarifies the 

tolerances the code developers intended to apply to hydrocarbon gas measurements. The amendment of 

Table T.2. will assist officials and industry by providing the exact tolerances applicable to hydrocarbon gas 

measurements and eliminate any need to borrow tolerances established and deemed appropriate for similar 

gas applications in this code (i.e., compressed natural gas) or from other code sections.
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OWM Executive Summary for

MFM-22.1 Table T.2. Accuracy Classes and Tolerances for Mass Flow Meters.

OWM Recommendation: OWM believes this item is fully developed and ready for a vote.

• This is a housekeeping item that clarifies the original tolerances (i.e., 2.0 percent and 1.0 percent) 

intended to apply in the dynamic measurement of hydrocarbon (HC) vapor products.

• Hydrocarbon vapor products application which has been recognized and remains unchanged in 

Application Section paragraph A.2. Vapor (Gases) of the MFM Code since the code was first adopted 

in 1991. 

• The proposal places the family of HC vapor products under an accuracy class designation (i.e., 2.0) 

which is required marking information specified in paragraph S.5.(e) Markings since January 1, 1995.

Table 3. Summary of Recommendations

MFM-22.1 Table T.2. Accuracy Classes and Tolerances for Mass Flow Meters

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered
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Item under Consideration:

Table T.2.

Accuracy Classes and Tolerances for Mass Flow Meters

Accuracy 

Class

Application or Commodity

Being Measured

Acceptance

Tolerance

Maintenance

Tolerance

Special

Tolerance

.

. 

.

.

. 

.

.

. 

.

.

. 

.

.

. 

.

2.0 - Compressed natural gas as a motor-fuel

- All other hydrocarbon gases and any 

other hydrocarbon gas/air mix 

applications not shown in the table

1.5 % 2.0 % 2.0 %

.

. 

. 

.

. 

. 

.

. 

. 

.

. 

. 

.

. 

. 

NIST OWM Detailed Technical Analysis: 

Prior to the NCWM amending the MFM Code in 1994 to introduce a new table format for tolerances, the 

code recognized maintenance and acceptance tolerances of 0.5 percent and 0.3 percent of the measured 

quantity for liquid-measuring devices and 2.0 percent and 1.0 percent for vapor-measuring devices, 

respectively.

The newly formatted table of tolerances did not include the hydrocarbon vapor products application which 

has been recognized and remains unchanged in Application Section paragraph A.2. Vapor (Gases) of the 

MFM Code since the code was first adopted in 1991. 

This proposal is a housekeeping item that clarifies the original tolerances (i.e., 2.0 percent and 1.0 percent) 

intended to apply in the dynamic measurement of hydrocarbon (HC) vapor products which should have 

carried over from the original performance requirements in paragraph format into the table format 

introduced in 1994. Consistent with the practice for other metered products throughout the MFM Code, 

the proposal places the family of HC vapor products under an accuracy class designation (i.e., 2.0) which 

is required marking information specified in paragraph S.5.(e) Markings since January 1, 1995.

During the 2022 CWMA Annual Meeting industry questioned whether the proposed tolerances would apply 

to hydrogen mixed with compressed natural gas (CNG). The proposal is intended to address all other 

hydrocarbon gases and any other hydrocarbon gas/air mix applications envisioned by the developers of this 

code. The specific blend ratios and the application for the blended product was not stated. Compressed 

natural gas (CNG)/hydrogen (H2) blended products for vehicle fueling do exist although the applicable 

tolerances for CNG are 1.5 % and 2.0 %, and those for hydrogen gas (See HB 44 Section 3.39 Hydrogen 

Gas-Measuring Devices Code) are 5.0 % and 7.0 %, respectively for type evaluation/new equipment and 

equipment in use. At this time CNG and hydrogen fall into two different product categories. The hydrogen 

code is intended to apply to hydrogen gas with a hydrogen fuel index above 99.97 % so it appears the MFM 

Code would be the code that applies to CNG/hydrogen blends. This might be a case where at certain 
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CNG/hydrogen blend ratios (by mass) further examination of data on the meter’s performance might be 

warranted.

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting. Based on comments in support of this item heard during the open 

hearings, the Committee recommends this item move forward with voting status.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Matt Douglas (California - DMS) : The language is clarifying. CA DMS supports this item.

Mr. Michael Keilty (Endress + Hauser) : states other gasses (hydrocarbon gasses). Solves issue with blended 

gasses. He supports this item.

The WWMA S&T Committee recommends that this item be assigned a Voting status. The Committee 

agrees that this item has merit and is fully developed.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Keilty, Endress+Hauser, commented that this item is 

a simple language cleanup from NIST, and that he supports moving it forward as a Voting item. This 

committee recommends moving this item forward as a Voting item. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Ms. Juana Williams (NIST OWM) commented that this is a housekeeping item that adds clarification. 

Michael Keilty (Endress+Hauser Flowtec), Lou Sakin, (Hopkinton/Northbridge, MA) and Jim Willis (New 

York) agreed with and recommended Voting Status for this item.

The NEWMA Specifications and Tolerances Committee recommends that this item be moved forward with 

a Voting Status.

During the 2022 Annual Meeting Open Hearing comments were heard during the open hearing.

Ms. Tina Butcher (NIST OWM) commented that this is a housekeeping item. The intent of this item is to 

add reference to all hydrocarbon gasses and mixtures to the tolerance table as they were inadvertently 

omitted during previous updates to this section of the handbook.

After hearing comments from the floor, the committee considered the item to be fully developed and 

recommended that the item retains voting status.

NEWMA recommends this proposal as a Voting Item on the NCWM agenda.
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Central Weights and Measures Association 

During the 2021 Interim Meeting Open Hearing the committee heard comments from the floor. Michael 

Keilty-Endress+Hauser Flow asked that item be moved to voting item.

CWMA S&T Committee recommends item move forward as a voting item.

During the 2022 Annual Meeting Open Hearing the following comments were heard during the open 

hearing session. Mr. Michael Keilty (Endress+Hauser) The proposed table T.2. mentions hydrogen. 

Hydrogen is a separate section. Would this apply to hydrogen mixed with CNG? Asked for explanation 

from NIST.

Ms. Lisa Warfield (NIST OWM) will provide clarification regarding the question about hydrogen mixing 

with CNG.

The CWMA S&T Committee recommends this moves forward as a voting item.

EVF – ELECTRIC VEHICLE FUELING SYSTEMS

EVF-21.1 D A.1. General

Source: ABB, BTCPower, Electrify America, Edison Electric Institute, EVConnect, EVgo, Greenlots, 

Rivian, Siemens, Tesla, Tritium

Purpose and Justification:

To provide clarity on how Handbook 44, Sec. 3.4 tentative code will apply to existing EVSE that are in the 

ground before it becomes effective by identifying which elements are non-retroactive.

OWM Executive Summary for EVF-21.1 – A.1. General

OWM Recommendation: OWM believes this item requires further development. Rather than 

proposing an exemption for all requirements in Section 3.40, OWM recommends the submitters propose

modifications to specific requirements to provide for alternative means of compliance. OWM 

acknowledges the submitters have been diligently working with the NIST USNWG EVFE Subgroup to 

identify possible alternatives for the submitters to present to the community for review.

• The proposal, if adopted as written, would mean an entire generation of devices will be permitted to 

operate for a 10-year period without having to comply with any HB 44 Section 3.40 requirements for 

indications, receipts, accuracy, security for metrological features, specific code markings, etc. for 

what may well be the lifetime of the device. 

• To allow such a blanket exemption does a disservice to the electric vehicle refueling industry and 

would be viewed as competitively unfair to traditional and other alternative vehicle fueling 

applications which are required to comply with similar requirements or EVSE manufacturers who are 

spending money to comply with current requirements. 

• The submitter needs to consider that, even if an effective date is added to an entire device-specific 

code, Section 1.10 General Code requirements will still apply.
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OWM Executive Summary for EVF-21.1 – A.1. General

• The submitters made alternate proposals available to the EVFE Subgroup in January 2022 and April 

2022. These alternate proposals do not include any modifications to paragraph A.1. General as shown 

in the Item under Consideration. 

• The EVFE Subgroup's discussions have been ongoing in their review of the submitters latest 

proposals which are intended to replace S&T Agenda Items EVF-21.1 and EVF-21.5. The EVFE has 

not reached a consensus on the submitters' latest proposals which were revised to address specific 

features such as the indicating element, identification/marking information, as well as general and 

type evaluation tolerances).

Table 3. Summary of Recommendations

EVF-21.1 A.1. General

V D W A I Notes* Comments

Submitter 

 See 9/28/20 industry presentation of the 

original proposal at WWMA. See also 

letters of 7/12/21 and 10/6/21 regarding 

proposed modifications to the original

proposal.

OWM

 See also OWM’s letter of 9/28/20

summarizing key points to consider.

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry 1 In addition to submitters’ 

letters noted above.

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered
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Item under Consideration:

A.1. General – This code applies to devices, accessories, and systems used for the measurement of 

electricity dispensed in vehicle fuel applications wherein a quantity determination or statement of 

measure is used wholly or partially as a basis for sale or upon which a charge for service is based.

A.1.1. Effective Dates for DC EVSE – All DC EVSE used for commercial purposes and put 

into service on or before January 1, 2023 are exempt from this standard for a period of 10 

years from the date put into service. comply 

A.1.2. Effective Dates for AC EVSE – All AC EVSE used for commercial purposes and put 

into service on or before January 1, 2022 are exempt from this standard for a period of 10 

years from the date put into service.

NIST OWM Detailed Technical Analysis: 

As the weights and measures community continues to consider proposed new paragraphs A.1.1 and A.1.2 

which would exempt EVSEs from all NIST HB 44 Section 3.40 requirements based on the dates these 

systems were placed into commercial use, NIST OWM would like to note the following concerns: 

As worded the proposal is: (1) unclear on the exact type of use that entitles an EVSE to an exemption from 

all code requirements and also (2) in conflict with General Code paragraph G-A.6. Nonretroactive 

Requirements. 

The proposal, if adopted, would mean an entire generation of devices will be permitted to operate for a 10-

year period without having to comply with any HB 44 Section 3.40 requirements for indications, receipts, 

accuracy, security for metrological features, specific code markings, etc. for what may well be the lifetime 

of the device. 

To allow such a blanket exemption does a disservice to the electric vehicle refueling industry and would be 

viewed as competitively unfair to traditional and other alternative vehicle fueling applications which are 

required to comply with similar requirements or EVSE manufacturers who are spending money to comply 

with current requirements. 

The submitter needs to consider that, even if an effective date is added to an entire device-specific code, 

Section 1.10 General Code requirements will still apply.

For jurisdictions that don’t automatically adopt the current version on NIST Handbook 44, this window of 

time during which noncompliant devices can continue to be installed will be even longer.

The USNWG EVF&S that developed the EVFSs Code and modified the Timing Device Code (to recognize 

EVSEs) has been widely advertised and all stakeholders (including EVFS OEMs) encouraged to join. 

Many companies have been an integral part of the development of these requirements and have expended 

considerable funds to bring their equipment into compliance at a competitive disadvantage if a large group 

of competing devices were to be exempted from the requirements. 

The proposal describes the marketplace as having “existing stations that often do not include an integrated 

meter” which might be an indication that available EVSEs placed into commercial use before the 

enforcement date will have limited or no legal metrology components. In this case a notice is necessary for 
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consumers that purchasing electricity from one site does not provide the same assurance of accuracy that is 

provided at another site. 

If there are concerns about specific provisions in the code, these need to be addressed by making specific 

sections “nonretroactive” with sunset dates, not by exempting the device from the requirements of the 

specific code in entirety. Factored into any enforcement dates should be the fact that the EVFS codes have 

been available for over six years (and was under development by regulators and industry for three years 

prior to that).

The submitters provided updates to the community in July 2021 about their work to revise the proposals in 

NCWM S&T Committee Agenda Items EVF-21.1 A.1. General and EVF-21.5 T.2. Load Test Tolerances. 

Their work was completed in early November 2021.

Throughout 2021 up through June 2022 NIST OWM has recommended the submitters revise their 2021 

proposals to address concerns previously expressed by the USNWG EVF&S’s EVFE Subgroup and weights 

and measures community prior to submission of any alternate proposals for a review of the EVFE Subgroup.

On November 20, 2021 NIST OWM provided input on the submitter’s alternate proposal. This revised 

proposal modifies five NIST Handbook 44 Section 3.40 EVFS requirements (that address indicating 

elements, sealing, identification/marking, and tolerances). The submitters and NIST OWM met on 

December 7, 2021 to discuss NIST OWM’s preliminary review and adjustments suggested for the alternate 

proposal. Subsequent revisions by the submitters of their alternate proposals were also made available to 

the EVFE Subgroup in January 2022 and April 2022. These alternate proposals do not include any 

modifications to paragraph A.1. General. The EVFE Subgroup’s discussions have been ongoing in their 

review of the submitters latest proposals which are intended to replace S&T Agenda Items EVF-21.1 and 

EVF-21.5. The EVFE has not reached a consensus on the submitters’ latest proposals.

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting. The Committee maintained the developing status for this item. The 

Committee suggests the submitters take into consideration the comments provided during open hearings 

and prepare a revised draft proposal to NIST OWM, the EVFE Subgroup, etc. to provide a comprehensive 

proposal to the membership.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Justin Wilson (ChargePoint): in the notes for 2021(Interim) there is an error: the notations are incorrect. 

They recommend withdrawal of this proposal. They think the flexibility should be provided to state 

officials. 

Kevin Schnepp (California - DMS) : extended exemptions are not appropriate - this is still tentative. This 

should be withdrawn.
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The WWMA S&T Committee recommends this item be withdrawn. The Committee makes this 

recommendation based on testimony heard during the open hearings and previous reports including 

recommendations from other Regions.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, the Committee received no comments on this item. This 

Committee recommends this item be Withdrawn due to the item allowing a 10-year exemption. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open hearings the following comments were heard.

Francesca Wahl (Tesla) speaking on behalf of the submitters group of EVSE companies asked for further 

development as the submitters work with the national work group to develop language that will satisfy 

regulators in-regards to time frames of implementation dates. Mr. Alex Beaton from EVgo supported 

Francesca’s comments and supports a development status.

Ms. Juana Williams (NIST OWM) commented in-regards to blanket exemptions that release devices from 

compliance for such an extended period-of-time seemed too long. (see NIST comments on NCWM website)

The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status.

During the 2022 Annual Meeting Open Hearing Ms. Tina Butcher (NIST OWM) commented that this item 

was originally submitted by a group of manufacturers. The item went to EV-USNWG, received feedback 

and the submitters have been working to address comments from national and regional levels. Mr. Beaton 

commented as one of the submitters. He indicated that the submitters heard feedback from regulators 

regarding the originally proposed 10-year exemption for EV meters and has modified the proposal. For 

DC meters, the submitters are looking to propose that all meters manufactured prior to 2024 will be subject 

to 5 % accuracy tolerance and those manufactured after 2024 will be subject to a 1 % accuracy tolerance. 

Both percentages for accuracy have been supported by data. For AC meters, Mr. Beaton indicated that 

prior changes to the proposal have been removed as the submitters believe with calibration, all meters can 

meet current code. Mr. Beaton believes the updated proposal will be available prior to the 2022 Annual 

Meeting.

After hearing comments from the floor, the Committee recognized the need to further develop this item and 

recommended the item retain developing status. The Committee suggested that the submitters continue to 

work with regulatory stakeholders and share data in order to further the development of the item and urges 

the timely submission of proposals for the Committee to review prior to annual and interim meetings. 

NEWMA recommends this proposal as a Developing Item on the NCWM agenda.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Tina 

Butcher-NIST has not seen a revised proposal from the submitters. Submitters recommend item stay 

developing.

CWMA S&T Committee recommends the item stay developing.
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During the 2022 Annual Meeting Open Hearings, Ms. Francesca Wahl (Tesl) working with NIST EVFE 

Subgroup to revamp the proposal and focusing on DC. Wants to remain development status. Supports 

current HB44 3.40 tentative code acceptance in the very near future.

The CWMA S&T Committee recommends this item remain as a developing item per the request of the 

submitter.

CWMA recommends this proposal as a Developing Item on the NCWM agenda.

EVF-20.1 V S.1.3.2. EVSE Value of the Smallest Unit.

Source: NIST Office of Weights and Measures

Purpose and Justification:

Specify the maximum permissible value of the indicated and/or recorded electrical energy unit by an EVSE. 

Establish a value for the energy unit of measurement (kilowatt-hour) that is suitable for all commercial 

transactions and does not significantly lengthen the time (by a factor of 25) to conduct a test of an EVSE.

OWM Executive Summary for EVF-20.1 – S.1.3.2. EVSE Value of the Smallest Unit.

OWM Recommendation: OWM believes the USNWG EVFE Subgoup’s “Option 3” alternative to the 

Item under Consideration as outlined in this analysis provides for a more appropriate resolution for AC

and DC systems and will help lessen rounding errors and confusion about the transaction.

• Based on findings over the past six years on the actual power capacity ranges EVSEs operate at and 

other standard practices in fueling EVs the EVFE Subgroups has deliberated to arrive at an alternate 

proposal to replace the current Item under Consideration in EVF-20.1. 

• At minimum the May-June 2022 EVFE Subgroup's proposed modifications that further refine 

paragraph S.1.3.2. EVSE Value of Smallest Unit should be adopted in July 2022. The Committee is 

also requested to consider proposed modifications to seven additional paragraphs for inclusion in 

EVF-20.1. 

• These latest proposed modifications to paragraph S.1.3.2. are similar to a suggested alternative 

proposal the NCWM S&T Committee reviewed in January 2022. This alternate rework of paragraph 

S.1.3.2. more appropriately recognizes the differences in AC and DC systems such as power levels. 

o The EVFE Subgroup's alternate reworked proposal (OPTION 3 below) includes a higher 

resolution for the AC system's displayed kWh (0.0001) but maintains the current handbook kWh 

(0.001) display resolution for a DC system; 

o further refines requirements for the expression of the kWh (as a value of 1) to lessen rounding 

errors and confusion about the transaction; and

o The U.S. standard will follow the SI practice of recognizing only the kWh for electrical energy 

in EV charging, so the megajoule will be no longer recognized in the EVFS Tentative Code.

• NIST OWM concurs with the EVFE SG's findings and its rework of paragraph S.1.3.2. EVSE Value 

of Smallest Unit (OPTION 3 below) and seven additional EVFS - Tentative Code requirements. 
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OWM Executive Summary for EVF-20.1 – S.1.3.2. EVSE Value of the Smallest Unit.

NIST OWM supports the EVFE SG proposed modifications to paragraphs: S.1.3.1. EVSE Units of 

Measurement; S.2.5.1. Money-Value Divisions Digital; S.8. Minimum Measured Quantity (MMQ); 

and removing unwarranted paragraphs N.1. No Load Test; N.2. Starting Load Test; T.5. No Load 

Test; and T.6. Starting Load. 

• These latest proposed modifications to paragraph S.1.3.2. are similar to a suggested alternate proposal 

the NCWM S&T Committee reviewed in January 2022. This January version of paragraph S.1.3.2. 

was a preview of a requirement that more appropriately recognized the differences in AC and DC 

systems such as power levels. The EVFE Subgroup's alternate reworked proposal (OPTION 3 below) 

includes a higher resolution for the AC system's displayed kWh but maintains the current handbook 

kWh display resolution for DC system and further refines requirements for the expression of the kWh 

to lessen rounding errors and confusion about the transaction.

Table 3. Summary of Recommendations

EVF-20.1 S.1.3.2. EVSE Value of Smallest Unit.

V D W A I Notes* Comments

Submitter 

 1 Developed May 2022 by the USNWG’s 

EVFE SG

OWM

 1 Developed May 2022 by the USNWG’s 

EVFE SG. Note OWM’s recommendations

in its letter of 9/28/20 have changed for this 

item EVF-20.1.

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered
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Item under Consideration:

S.1.3.2. EVSE Value of Smallest Unit. – The value of the smallest unit of indicated delivery by 

an EVSE, and recorded delivery if the EVSE is equipped to record, shall be 0.005 MJ or 0.001 

kWh.: 

(a) for AC and DC systems shall not exceed 0.0005 MJ or 0.0001 kWh; and

(b) the value in electrical energy units in terms of:

(1) the megajoule (MJ) shall be expressed as a decimal multiple or submultiple of 5; 

or 

(2) the kilowatt hour (kWh) shall be expressed as a decimal multiple or submultiple 

of 1.

(Amended 2022)

NIST OWM Detailed Technical Analysis:

In 2020 NIST OWM went forward with the proposed value (i.e., 0.0005 MJ [0.0001 kWh]) because during 

the 2014 USNWG EVF&S deliberations on the draft code, industry representatives indicated that the size 

or value of the electrical energy smallest unit of measurement could be inexpensively modified and to align 

U.S. EVSE design requirements with the EVSE code about to be adopted by California.

NIST OWM notes that the USNWG’s EVF&S Electric Vehicle Fueling Equipment Subgroup did not reach 

a consensus on the proposed or alternate language for this agenda item. On July 7, 2020, the subgroup 

assigned the proposal to a new subcommittee chaired by Dr. William Hardy to fully address the effect of 

the EVSE’s display resolution and MMQ size on the testing time for AC and DC systems. The proposal is 

still in subcommittee. Chair Hardy has made several preliminary modifications to paragraph S.1.3.2. The 

EVFE Subgroup requested input from all sectors (OEMs, Regulators, Consumer Associations, Operators) 

on their perspective from an ease of testing standpoint, transparency, and for easy comparison to other 

traditional and alternative vehicle fueling applications, what should the maximum or fixed increment size 

be for sales of electrical energy vehicle fuel (in the XXXX.X kWh)? Beyond California advocating a higher 

resolution and New York finding the current increment size as workable no further input has been received. 

By close of 2021 no weights and measures laboratory/agency has conducted testing on DC systems due to 

the availability of test apparatus.

NIST OWM recognizes the proposal’s status has remained developing throughout 2020-2021 but notes that 

California adopted and is now enforcing its permanent EVFS Code that requires the smallest unit of 

electrical energy indicated and recorded be in higher resolution increments either equivalent to but not 

greater than 0.0001 kWh. As of December 2021, California has issued certificates of type approval to 

eleven models of EVFSs, eight for systems designed with a 0.0001 kWh and three with a 0.000001 kWh 

electrical energy unit of measurement. OEMs seeking NTEP and California type approval must design a 

system that has a fixed 0.001 kWh increment and for systems in commercial use in California the value of 

that measurement unit shall not exceed 0.0001 kWh, respectively. 

Other NIST Handbook 44 measuring devices’ codes specify the value of the unit permitted for the display 

and indication of a delivered or dispensed quantity. In all cases that value shall not be exceeded (i.e., 

prescribes a maximum numerical value where a lesser value is also permissible) and is suitable for each 

device-specific application. 

After its July 2021 reevaluation of the proposed modifications to this EVSE provision in paragraph S.1.3.2, 

NIST OWM is renewing its support for the proposal that currently appears in EVF 20.1 Item under 
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Consideration. In that same spirit NIST OWM also has developed an additional recommendation, a 

proposed new subparagraph S.1.3.2, which is consistent with the language in other code sections’ 

corresponding requirements which prescribe specific values for indicating units. The newly proposed 

paragraph is a better option for addressing OWM’s earlier concerns about value comparisons and clarity of 

electrical energy sales when computing and rounding transaction information if an EVSE were ever 

designed with an electrical energy unit value expressed as 3, 7, or 9. Also now in question would be the 

expression of the unit in any other numerical value that might introduce questions about rounding

calculations and the transparency of the transaction. NIST OWM recommends the community reconsider 

the original proposed modifications of paragraph S.1.3.2 which does not limit the electrical energy unit to 

being expressed only as a single fixed numerical value but permits a manufacturer to design a display that 

measures in a numerical value of 0.0005 MJ or 0.0001 kWh or some other numerical value as long as the 

chosen value does not exceed those MJ or kWh maximum values specified in paragraph S.1.3.2. Whatever, 

the quantity unit value it would remain unchangeable during the commercial use of the system or dispenser. 

Also, the test apparatus’ display resolution must be suitable and does not use up the allow error for the 

EVSE under test. The current proposal does not specify a different value for the smallest display unit for 

DC systems. However, the USNWG EVFE Subgroup’s Technical Advisor was advised that the current 

required value of 0.001 kWh might be more suitable for DC systems. NIST OWM has revised its earlier 

proposal and recommends an alternate paragraph S.1.3.2 to include two new subparagraphs that requires 

the EVSE’s smallest value indicated or recorded be the equivalent of and shall not exceed 0.0005 MJ 

(0.0001 kWh) and specify the permissible electrical energy unit value shall only be expressed as either 

decimal multiples or submultiples of the number 1 when the unit of measurement is the kWh and 5 when 

the unit of measurement is the MJ as shown below in: 

OPTION 1

S.1.3.2. EVSE Value of Smallest Unit. – The value of the smallest unit of indicated delivery by 

an EVSE, and recorded delivery if the EVSE is equipped to record, shall be 0.005 MJ or 0.001 

kWh.:

(a) for AC and DC systems shall not exceed 0.0005 MJ or 0.0001 kWh; and

(b) the value in electrical energy units in terms of:

(1) the megajoule (MJ) shall be expressed as a decimal multiple or submultiple of 5; or 

(2) the kilowatt hour (kWh) shall be expressed as a decimal multiple or submultiple of 1.

It should be noted that all four regional associations in fall 2021 supported the Item under Consideration as 

a Voting item. NIST OWM anticipates the upcoming availability of test data on DC systems may 

demonstrate that further modifications may be necessary to adequately address DC systems in the code. 

This may result in modifications to paragraph S.1.3.2 to read in:

OPTION 2

S.1.3.2. EVSE Value of Smallest Unit. – The value of the smallest unit of indicated delivery by 

an EVSE, and recorded delivery if the EVSE is equipped to record, shall be 0.005 MJ or 0.001 

kWh.:

(a) for AC systems shall not exceed 0.0005 MJ or 0.0001 kWh; 
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(b) for DC systems shall not exceed 0.005 MJ or 0.001 kWh; and

(c) the value in electrical energy units in terms of:

(1) the megajoule (MJ) shall be expressed as a decimal multiple or submultiple of 5; or 

(2) the kilowatt hour (kWh) shall be expressed as a decimal multiple or submultiple of 1.

NIST OWM supports the May-June 2022 USNWG EVFE Subgroup’s alternate proposal shown below that 

is a rework of EVF-20.1. The USNWG EVF&S’s Electric Vehicle Fueling Equipment (EVFE) Subgroup 

submits the following recommendations for further modification of S&T Committee Agenda Item EVF20.1, a proposal to modify NIST Handbook 44 Section 3.40 Electric Vehicle Fueling Systems Code 

paragraph S.1.3.2. EVSE Value of Smallest Unit. The EVFE Subgroup recommends all eight paragraphs 

shown below move forward for adoption in July 2022 under EVF-20.1. The recommendation is the result 

of six years of testing and consultations with manufacturers, laboratory evaluators, and officials testing 

EVSEs. At minimum the EVFE Subgroup proposes its recommended modifications to paragraph S.1.3.2. 

should be adopted in July 2022 because the AC systems’ requirements for a display unit value not greater 

than 0.0001 kWh are aligned with the national proposal and due to the power levels for DC systems the 

EVFE Subgroup recommends keeping the value of the kWh unit as it currently appears in the NIST HB 44 

design requirement (0.001 kWh or smaller), which is more appropriate. The EVFE Subgroup’s 

recommendation for no change to the value of the DC EVSE smallest display unit is actually less of a 

change for DC systems than the amendment for DC systems the S&T Committee currently recommends. 

The 0.0001 kWh resolution for AC EVSE is necessary to conduct testing to determine compliance with 

accuracy requirements in minimal time. The current resolution of 0.001 kWh required for AC systems 

would result in 25 % of the EVSE tests being incorrectly evaluated on a pass/fail basis. The EVFE Subgroup 

also recommends removing all reference in the code to the megajoule (MJ) since this unit of measurement 

is not recognized for electrical energy in the SI system.

OPTION 3 (May 2022 EVFE Subgroup’s rework of paragraph S.1.3.2.)

S.1.3. EVSE Units. 

S.1.3.2. EVSE Value of Smallest Unit. – The value of the smallest unit of indicated delivery by 

an EVSE, and recorded delivery if the EVSE is equipped to record, shall be 0.005 MJ or 

0.001 kWh.:

(a) for AC systems shall not exceed 0.0001 kWh; 

(b) for DC systems shall not exceed 0.001 kWh; and

(c) the value of the kWh shall be expressed only as a decimal submultiple of 1 that 

satisfy (a) and (b). 

(Amended 202X)

The EVFE Subgroup developed recommendations for also modifying the following paragraph and 

definition to eliminate the use of the megajoule unit of measurement:
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S.1.3.1. EVSE Units of Measurement. – EVSE units used to charge electric vehicles shall be 

indicated and recorded in megajoules (MJ) or kilowatt-hours (kWh) and decimal subdivisions 

thereof.

(Amended 202X)

megajoule (MJ). – An SI unit of energy equal to 1 000 000 joules (J). [3.40]

The computed total price for the sale of electrical energy shall be based on an EVSE using a quantity interval 

that does not exceed 0.01 kWh, rather than the interval of 0.1 kWh currently required, and not indicate in 

units of the megajoule. Consequently, the EVFE Subgroup proposes modifying the quantity value and also 

recommends removing the megajoule unit of measurement from paragraph S.2.5.1. Money-Value Divisions 

Digital as shown below:

S.2.5.1. Money-Value Divisions Digital. – An EVSE with digital indications shall comply with 

the requirements of paragraph G-S.5.5. Money-Values, Mathematical Agreement, and the total 

price computation shall be based on quantities not exceeding 0.5 MJ or 0.01 kWh.

(Amended 202X)

The EVFE Subgroup recommends modifying paragraph S.8. Minimum Measured Quantity (MMQ) to 

recognize an MMQ of 0.1 kWh which is very common among EVSE that have already been type approved. 

For ANSI C12 compliant meters meter constants of 0.001 kWh are common. In these meters the meter is 

expected to be fully accurate at deliveries of only a single watthour (i.e., 0.001 kWh). Dispensing a larger 

amount of energy to determine accuracy is not needed. Additionally, the EVFE Subgroup recommends 

paragraph S.8 specify an MMQ not to exceed 1.0 kWh as a more appropriate quantity for DC systems and 

include a new note to encourage a smaller MMQ for EVSEs which in the case of AC systems will result in 

a shorter time to conduct a test by a factor of five. This proposed modification of paragraph S.8 also 

resolves the lengthy time required to conduct a proper test of the system; a concern in 2020 that prompted 

work to modify code requirements that affected the duration of the tests. 

S.8. Minimum Measured Quantity (MMQ). – The minimum measured quantity shall satisfy the 

conditions of use of the measuring system as follows:

(a) Measuring systems shall have a minimum measured quantity not exceeding 2.5 MJ or:

(1) 0.5 kWh for AC EVSE; and

(2) 1.0 kWh for DC EVSE.

Note: To minimize the duration of required testing, manufacturers may want to consider limiting 

the declared MMQ to the level of 0.1 kWh for AC EVSE. 

(Amended 202X)

The EVFE Subgroup also recommends removing the No Load Test and Starting Load Test notes and their 

corresponding tolerances from the code requirements because these conditions are never encountered by a 

customer. An EVSE never operates at no load for any significant time. The Starting Load Test should not 

be required because the EVSE never operates at 0.5A. Consequently, also modify the relevant handbook 

requirements as follows:
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N.1. No Load Test. – A no load test may be conducted on an EVSE measuring system by applying 

rated voltage to the system under test and no load applied.

T.5. No Load Test. – An EVSE measuring system shall not register when no load is applied. 

N.2. Starting Load Test. – A system starting load test may be conducted by applying rated voltage 

and 0.5-ampere load.

T.6. Starting Load. – An EVSE measuring system shall register a starting load test at a 0.5 ampere 

(A) load.

Renumber paragraph N.3. Minimum Test Draft (Size) through N.6. Repeatability Tests to become N.1. 

through N.4., respectively. 

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting. The Committee has considered the three options provided by the 

submitter, NIST OWM. Proposal 1, as it appears in Publication 15 and the two alternative proposals 

published in NIST OWM’s written analysis. The Committee has considered the three proposals and has 

agreed the item is fully developed and is supported by current AC EVSEs in commercial use. The 

Committee understands there may be more data available at the time of vote providing additional 

information on the value of the smallest unit in DC EVSE systems. The Committee agreed with 

recommendations that Proposal 1, which appeared in the Item under Consideration in the January 2022 

S&T Agenda and shown below, should be further modified to clarify the permissible numerical values for 

expressing the unit of measurement (i.e., MJ or kWh):

S.1.3. EVSE Units. 

S.1.3.2. EVSE Value of Smallest Unit. – The value of the smallest unit of indicated delivery by 

an EVSE, and recorded delivery if the EVSE is equipped to record, shall not be greater than 

0.0005 MJ or 0.0001 kWh. 

(Amended 2020) 

Committee has assigned a voting status for the item as shown below at the 2022 Annual Meeting. This 

alternate proposal replaces Proposal 1 in the Item under Consideration to read as follows: 

S.1.3.2. EVSE Value of Smallest Unit. – The value of the smallest unit of indicated delivery by 

an EVSE, and recorded delivery if the EVSE is equipped to record, shall be 0.005 MJ or 0.001 

kWh.: 

(a) for AC and DC systems shall not exceed 0.0005 MJ or 0.0001 kWh; and

(b) the value in electrical energy units in terms of:

(1) the megajoule (MJ) shall be expressed as a decimal multiple or submultiple of 5; or 

(2) the kilowatt hour (kWh) shall be expressed as a decimal multiple or submultiple of 1. 
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Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Kevin Schnepp (California - DMS) : Supports this item. This was adopted in California and helped in time 

of testing. It would be beneficial to all (less timely). In support.

Tina Butcher (NIST OWM) : Echoes what Kevin Schnepp indicated: the proposed change will align with 

California standards - no alternative suggestions have been made yet. Move to a vote to get in alignment.

The WWMA S&T Committee recommends that this item be assigned a Voting status. The Committee 

agrees that this item has merit and is fully developed.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the committee received no comments on this item. This 

committee recommends the item move forward as a Voting item.

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Jim Willis (New York) commented in-regards to the value of the smallest unit. NY has tested many 

charging stations that have a resolution to the thousands place and have not experienced any issues with 

this. The additional decimal place in New York’s opinion is not needed and may place an unneeded 

requirement for some companies in the industry. 

Ms. Juana Williams (NIST OWM) commented that the proposed change aligns the requirement with those 

already adopted and in use by the California Division of Measurement Standards. This alignment is needed 

to ensure consistency in inspection and testing of Electric Vehicle Fueling Systems in both type evaluation 

and field inspection and testing. NIST OWM notes that the NIST U.S. National Work Group has discussed 

the possibility that additional changes may be needed to this paragraph; however, no specific 

recommendations have been suggested to this point and do not appear to be imminent. Thus, to avoid 

inconsistencies noted above and delays in inspecting and testing this equipment, the Committee may wish 

to move this item forward for a vote.

Mr. Jim Willis (New York) commented that alignment with California is not a reason to change something 

that is working as intended. And that New York does not believe this change is necessary.

The NEWMA Specifications and Tolerances Committee recommends that this item move forward as a 

Voting item.

During the 2022 Annual Meeting open hearing Ms. Tina Butcher (NIST OWM) commented that the 

language in the handbook conflicts with what California DMS was applying in the field. The USNWG is 

still working on the proposal and may have additional changes by the Annual Meeting. Mr. James Cassidy 

(Massachusetts) commented that due diligence should be made to properly vet any changes to this proposal.
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After hearing comments from the floor, the Committee agreed to recommend this item retain Voting status, 

however, urges the timely submission of proposals for committee to review prior to annual and interim 

meetings. 

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearings the committee heard comments from the floor. Diane LeeNIST and Mrs. Tina Butcher (NIST OWM) recommend this item for Voting as it is in line with California.

CWMA S&T Committee recommends this item as a Voting item.

During the 2022 Annual Meeting Open Hearing no comments were heard from the floor. The CWMA 

S&T Committee recommends this moves forward as a voting item. CWMA recommends this proposal as 

a Voting Item on the NCWM agenda. 

EVF-21.5 D T.2. Load Test Tolerances.

Source: ABB, BTCPower, Electrify America, Edison Electric Institute, EVConnect, EVgo, Greenlots, 

Rivian, Siemens, Tesla, Tritium

Purpose and Justification:

To create separate metering requirements for DC EVSE due to significant technology differences and 

challenges between AC and DC systems.

OWM Executive Summary for T.2. Load Test Tolerances

OWM Recommendation: OWM believes this item requires further development. OWM acknowledges 

the submitters have been diligently working with the NIST USNWG EVFE Subgroup to identify possible 

alternatives for the submitters to present to the community for review.

• The EVFE Subgroup’s discussions have been ongoing in their review of alternate proposals reworked 

by the submitters for expanding tolerances to 5 % for DC charging equipment manufactured prior to 

a specific date and maintaining the 1 % acceptance and 2 % maintenance tolerances for equipment 

manufactured after that date.

o Proposals discussed recommend these changes be accompanied by a new marking requirement

for those devices not capable of meeting the 1 % acceptance and 2 % maintenance tolerances to 

alert consumers of the difference in performance levels.

• The EVFE Subgroup was balloted June 17, 2022 on a proposed new 5 % tolerance for DC EVSEs 

installed prior to 2024 and a corresponding new requirement for marking the accuracy of pre-2024 

equipment.

o The results of this ballot will be provided to the submitters to enable them to assess how and if to 

modify their original proposal to the S&T Committee.

• OWM notes that a sunset date (retroactive enforcement date) ending a dual tolerance structure would 

encourage uniformity in equipment performance in the marketplace; facilitate value comparisons by 

consumers; and phase out less accurate equipment.
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OWM Executive Summary for T.2. Load Test Tolerances

• According to information provided to the USNWG by the submitters, not all DC chargers (including 

those manufactured in recent years) manufactured prior to 2024 can be readily or inexpensively 

upgraded to meet the existing (1 % and 2 %) tolerances. 

o Of the DC chargers manufactured prior to 2024, including those manufactured in recent years, 

some are capable of being upgraded to meet the existing (1 % and 2 % tolerances) and some are 

not.

o Of those DC chargers that can be upgraded, the cost for such upgrades can vary across a rather 

wide spectrum.

o While some estimates of impact have been provided, the details seem to represent the broad 

spectrum of capabilities and cost, making it difficult to assess the impact on manufacturers, 

businesses, and consumers as a whole. 

o Details regarding the percentage of equipment that falls into these categories would be helpful to 

the community in assessing the need for a sunset date and, if a sunset date is deemed appropriate, 

what represents a reasonable time frame for phasing out the less accurate equipment. 

o Information has also been provided to suggest that newer DC devices being manufactured

(including those manufactured today) are more robust than older equipment, extending the lifespan 

beyond that originally reported in past discussions.

Table 3. Summary of Recommendations

EVF-21.5 D T.2. Load Test Tolerances.

V D W A I Notes* Comments

Submitter 

 See also letters of 7/12/21 and 10/6/21 

regarding proposed modifications to the 

original proposal.

OWM

 See also OWM’s letter of 9/28/20 

summarizing key points to consider.

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry 1 In addition to submitters’ 

letters noted above.

Manufacturers

Retailers and Consumers
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Table 3. Summary of Recommendations

EVF-21.5 D T.2. Load Test Tolerances.

V D W A I Notes* Comments

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

5 - No recommendation or not considered

Item under Consideration:

T.2. Load Test Tolerances.

T.2.1. AC EVSE Load Test Tolerances. – The tolerances for AC EVSE load tests are:

(a) Acceptance Tolerance: 1.0 %; and 

(b) Maintenance Tolerance: 2.0 %.

T.2.2. DC EVSE Load Test Tolerances. – The tolerances for DC EVSE load tests:

(a) Devices installed prior to January 1, 2033

i. Acceptance Tolerance: 2.5 %; and 

ii. Maintenance Tolerance: 5.0 % 

(b) Devices installed January 1, 2033 or later

i. Acceptance Tolerance: 1.0 %; and 

ii. Maintenance Tolerance: 2.0 % 

NIST OWM Detailed Technical Analysis:

As the weights and measures community continues to consider proposed new paragraph T.2.2 which would 

widen the tolerances for DC systems “installed” prior to January 1, 2033, NIST OWM asks are there 

existing devices that can meet the current requirements? If there are, what are the justifications for 

proposing the relaxing of the tolerances, particularly without a sunset date (i.e., a retroactive date)?

From a technical perspective, OWM would be less reluctant to seeing the adoption of a phase-in date that 

includes an accompanying sunset date (i.e., a retroactive date). OWM asks what concrete issues can be 

cited by the submitters to counter any opposing arguments for a phase in period for DC systems? It would 

be important to have statistics on the population of devices not in compliance with requirements as 

discussion moves forward on this proposal.
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This is not a typical practice to be done on an unlimited basis. This would be more palatable from both a 

competitive and enforcement standpoint if there are specific technical issues, that necessitate and justify 

relaxing tolerances on an industrywide basis. An additional concern is that companies are spending money 

to comply with the existing NIST HB section 3.40 tentative code yet are competing with a population of 

existing equipment. An additional question is: how big is that population exactly?

NIST OWM also would ask how many devices are out there that would be put into use and competing with 

AC devices, thus creating a competitive advantage for DC devices?

There will be concerns about a dual tolerance structure since the original proposal didn’t include a 

corresponding marking or some other type of information requirement to alert consumers that purchasing 

electricity from one fueling device does not provide the same accuracy assurance as it does from another 

fueling device. Bottom line multiple tolerance tiers frustrate value comparisons. There is not a lot of data 

being made available on the accuracy of DC devices. Comments from the EVFE Subgroup representatives 

from industry and national laboratory indicate the current 1 % acceptance and 2 % maintenance tolerances 

are achievable by existing DC systems. NIST OWM was made aware in June 2022 that at least one 

jurisdiction is in possession of a DC standard that has traceability. Several EVFE Subgroup members 

indicate there is a confidentiality issue that prevents release of any data. 

Throughout 2021 up through mid-2022 NIST OWM has recommended the submitters revise their 2021 

proposals to address concerns previously expressed by the USNWG EVF&S’s EVFE Subgroup and weights 

and measures community prior to submission of any alternate proposals for a review of the EVFE Subgroup.

The submitters provided updates to the community in July 2021 about their work to revise the proposals in 

NCWM S&T Committee Agenda Items EVF-21.1 A.1. General and EVF-21.5 T.2. Load Test Tolerances. 

Their work was completed in early November 2021. 

On November 20, 2021, NIST OWM provided input on the submitter’s alternate proposal. This revised 

proposal modifies five NIST Handbook 44 Section 3.40 EVFS requirements (that address indicating 

elements, sealing, identification/marking, and tolerances). The submitters and NIST OWM met on 

December 7, 2021 to discuss NIST OWM’s preliminary review and adjustments suggested for the alternate 

proposal. Subsequent revisions by the submitters of their alternate proposals were also made available to 

the EVFE Subgroup in January 2022 and April 2022. The EVFE Subgroup’s discussions have been 

ongoing in their review of the submitters proposals for expanding tolerances to 5 % for older equipment in 

commercial operation and EVSE marking requirements if a dual tier tolerance structure exists. The EVFE 

Subgroup was balloted June 17, 2022 on a proposed new 5 % tolerance for DC EVSEs installed prior to 

2024 and a corresponding new requirement for marking the accuracy of pre-2024 equipment.

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting. During the Committee work session this item was assigned Developing 

status. The Committee suggests the submitters take into consideration the comments provided during open 

hearings. The Committee recommends the submitters work with NIST OWM on the final draft of their 

2022 alternate proposal for review and comments.

Regional Association Reporting:

Western Weights and Measures Association
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During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Kevin Schnepp (California - DMS): this was adopted in California Regulation. Just this past week 

(September 23rd 2021) a complete analysis was done and clearly identified that they can meet the 1% 

tolerance. Recommends to be withdrawn.

Mr. Justin Wilson (ChargePoint) : Recommend to be withdrawn - equipment can meet tolerance as is

Mr. Keith Bradley (Electrify America): There are two questions: 1 - can devices in near term meet the 

tolerance? They are concerned with: when did this become possible? They are continuing to work on this. 

They are not urging changes to this item - they are working on it. Wants to leave it in developing status -

more work to be done.

Mr. Kurt Floren (Los Angeles County): when equipment is out there that is meeting the standards, this is 

not the time to roll back.

The WWMA S&T Committee recommends this item be Withdrawn. The Committee makes this 

recommendation based on testimony heard during the open hearings and previous reports including 

recommendations from other Regions.

Southern Weights and Measures Association

At the 2021 SWMA Open Hearing the committee received no comments on this item. 

This Committee recommends this item be Withdrawn because we believe that current tolerances are 

attainable.

Northeastern Weights and Measures Association

During the 2021 Interim Meeting open hearings, the following comments were heard.

Ms. Francesca Wahl (Tesla) representing the submitting group commented and was supported by Mr. Alex 

Beaton (EV GO) in-regards to a study and follow up WebEx meeting from Argonne National Lab. In-order 

to follow up on this study, the submitters are asking for a developing status.

Ms. Juana Williams (NIST OWM) commented below and comments can also be found on the NCWM 

website. 

1. NIST OWM asks if there are existing devices that can meet the current requirements? If there are, 

what are the justifications for proposing the relaxing of the tolerances, particularly without a sunset 

date (i.e., a retroactive date)?

2. From a technical perspective, OWM would be less reluctant to seeing the adoption of a phase-in 

date that includes an accompanying sunset date (i.e., a retroactive date). OWM asks what concrete 

issues can be cited by the submitters to counter any opposing arguments for a phase in period for 

DC systems? It would be important to have statistics on the population of devices not in compliance 

with requirements as discussion moves forward on this proposal.
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3. This is not a typical practice to be done on an unlimited basis. This would be more palatable from 

both a competitive and enforcement standpoint if there are specific technical issues, that necessitate 

and justify relaxing tolerances on an industrywide basis. An additional concern is that companies 

are spending money to comply with the existing NIST HB section 3.40 tentative code yet are 

competing with a population of existing equipment. 

4. NIST OWM also would ask how many devices are out there that would be put into use and 

competing with AC devices, thus creating a competitive advantage for DC devices?

5. There will be concerns about a dual tolerance structure since the proposal doesn’t include a 

corresponding marking or some other type of information requirement to alert consumers that 

purchasing electricity from one fueling device does not provide the same accuracy assurance as it 

does from another fueling device. Bottom line multiple tolerance tiers frustrate value comparisons.

NEWMA recommended this as a Developing Item on the NCWM agenda.

During its 2022 Annual Meeting Open Hearing NEWMA heard from:

Mrs. Tina Butcher (NIST OWM) commented that this item was originally submitted by a group of 

manufacturers. The item went to EV-USNWG, received feedback and the submitters have been working 

to address comments from national and regional levels. 

Mr. Alex Beaton (EVgo) commented as one of the submitters. He indicated that the submitters heard 

feedback from regulators regarding the originally proposed 10-year exemption for EV meters and has 

modified the proposal. For DC meters, the submitters are looking to propose that all meters manufactured 

prior to 2024 will be subject to 5 % accuracy tolerance and those manufactured after 2024 will be subject 

to a 1 % accuracy tolerance. Both percentages for accuracy have been supported by data. For AC meters, 

Mr. Beaton indicated that prior changes to the proposal have been removed as the submitters believe with 

calibration, all meters can meet current code. Mr. Beaton believes the updated proposal will be available 

prior to the 2022 Annual Meeting.

After hearing comments from the floor, the Committee recognized the need to further develop this item and 

recommended the item retain developing status. The Committee suggested that the submitters to continue 

to work with regulatory stakeholders and share data in order to further the development of the item and 

urges the timely submission of proposals for committee to review prior to annual and interim meetings.

NEWMA recommends this proposal as a Developing Item on the NCWM agenda. 

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the committee heard comments from the floor. Diane LeeNIST noted that there were comments regarding this item on the NCWM website.

CWMA S&T Committee recommends this item be withdrawn.

During its 2022 Annual Meeting Open Hearing, the CWMA heard from:

Mr. Keith Bradley (Electrify America) Thanks to NIST for forming the work group. Industry has worked 

hard to determine compliance for existing devices. DC fast chargers already installed will have a larger 

retroactive tolerance. Recommended to remain as developing.
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Ms. Francesca Wahl (Tesla) Minor modifications outside of tolerances will still be needed in order for 

manufacturers to comply with changes to devices already in commercial use.

Mr. Charlie Stutesman (Kansas) HB 44 3.40 tentative code has been in place for 7 years. It needs to become 

active and enforceable.

The CWMA S&T Committee recommends this item remain as a developing item per the request of the 

submitter.

The CWMA recommends the proposal as a Developing Item on the NCWM agenda. 

TXI – TAXIMETERS

TXI-22.1 V Table S.5. Categories of Device and Methods of Sealing 

Source: NIST Office of Weights and Measures

Purpose and Justification:

To provide additional electronic means of sealing for taximeters and eliminate confusion regarding the use 

of the term “electronic link” in that HB 44 Code. 

OWM Executive Summary for TXI-22.1 – Table S.5. Categories of Device and Methods 

of Sealing

OWM Recommendation: OWM believes this item is fully developed and ready for a vote. This change 

will provide the specificity needed for audit trail criteria for taximeters and will allow this method of 

security for these devices.

• The proposal recognizes other approved means of security, an audit trail for electronically 

securing taximeter sealable parameters given the limited size of the taximeter and multiple 

options for electronically adjustable taximeter components.

Use of an "electronic link" has been recognized since 2000 and remains a means to ensure the 

taximeter in operation is calibrated to the vehicle. Paragraph S.5.2. Taximeters Calibrated to 

Specific Vehicles adequately addresses the requirement for this security feature and does not 

need to remain in Table S.5.

Table 3. Summary of Recommendations

TXI-22.1 Table S.5. Categories of Device and Methods of Sealing 

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 
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Table 3. Summary of Recommendations

TXI-22.1 Table S.5. Categories of Device and Methods of Sealing 

V D W A I Notes* Comments

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Table S.5. 

Categories of Device and Methods of Sealing

Categories of Device Methods of Sealing

Category 1: No remote configuration capability. Seal by physical seal or two event counters: one for 

calibration parameters and one for configuration 

parameters., for components that may be removed 

from the vehicle, a combination of physical seals 

and a physical or electronic link as described in 

S.5.2. Taximeters Calibrated to Specific Vehicles.

[Nonretroactive as of January 1, 2018]

(Table Added 2017) (Amended 2022)

NIST OWM Detailed Technical Analysis: 

The current NIST HB 44 Section 5.54 Taximeters Code Table S.5. Method of Sealing Category 1 taximeters 

recognizes only a physical seal or electronic link as a means for securing a taximeter’s metrological 

parameters. Other approved means of security such as the audit trail is appropriate for securing taximeter 

sealable parameters given the limited size and options for electronically adjustable taximeter components. 

This proposal modifies Category 1 sealing requirements to recognize the audit trail form of device security.
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Since 2000 the use of an “electronic link” has been recognized as an alternative to a physical seal as a form 

of security for conditions of use where a taximeter is removed temporarily from service and more 

specifically from the vehicle it was calibrated to.

Requirements for the design and conditions of use for an “electronic link” are already adequately addressed 

in paragraph S.5.2. Taximeters Calibrated to Specific Vehicles and do not need to remain in Table S.5.

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting. The Committee agrees the item as having merit and will align this code 

with other device codes. Based on no opposition and the submitter’s request for a vote, the committee has 

assigned a voting status for this item at the 2022 Annual Meeting with the added three parenthetical dates: 

enforcement date, date of inclusion in the code, and the 2022 amendment.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Tina Butcher (NIST OWM) : They put this forward: the recommended changes are just to clarify what is 

already in place for audit trails. This is to fill in the blanks for what is considered the minimum for audit 

trails. This specifies two event counters for the minimum form of an audit trail.

The WWMA S&T Committee recommends that this item be assigned a Voting status. The Committee 

agrees that this item has merit and is fully developed.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing, the SWMA S&T Committee heard no comments on this 

item. 

The SWMA recommends this item move forward as a Voting item. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Ms. Juana Williams (NIST OWM) commented in support and feels the item is fully developed and ready 

for voting status. 

Mr. Jim Willis (New York) and Mr. John McGuire (New Jersey) also supported moving this item forward 

with a voting status.

The NEWMA Specifications and Tolerances Committee recommends that this item be given a Voting 

Status.
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During the 2022 Annual Meeting Open Hearing comments were heard from Ms. Tina Butcher (NIST 

OWM) that the goal of this item is to get specificity into the handbook regarding the minimum standards 

for event counter, electronic audit trails, and eliminate reference to prohibit it.

After hearing comments from the floor, the committee considered the item to be fully developed and 

recommended that the item retain voting status. CWMA recommends the proposal as a Voting Item on the 

NCWM agenda. 

Central Weights and Measures Association 

During the 2021 Interim Meeting Open Hearing the committee heard comments from the floor. Tina 

Butcher-NIST recommends that this item move forward to voting. California has this in type evaluation 

now.

CWMA S&T Committee recommends this item move forward as a voting item.

During the 2022 Annual Meeting Open Hearing no comments were heard from the floor.

The CWMA S&T Committee recommends this moves forward as a voting item. CWMA recommends the 

proposal as a Voting Item on the NCWM agenda. 

GMA – GRAIN MOISTURE METERS 5.56 (A)

GMA-19.1 D Table T.2.1. Acceptance and Maintenance Tolerances Air Oven Method for All 

Grains and Oil Seeds.

Source: NTEP Grain Analyzer Sector

Purpose and Justification:

Reduce the tolerances for the air oven reference method.

OWM Executive Summary for GMA-19.1 – Table T.2.1. Acceptance and Maintenance 

Tolerances Air Oven Method for All Grains and Oil Seeds.

OWM Recommendation: NIST OWM support the collection of data to verify that the proposed 

reduction in tolerances is appropriate for all grains.

• During the NTEP Grain Analyzer (GA) Sector 2019 meeting, the Sector reviewed data from Arkansas 

for Long Grain Rough Rice (LGRR) and other grains. The data showed that the proposal to tighten 

the acceptance and maintenance tolerance may not be appropriate for all grain types. The original 

data presented and used as a basis for the proposal applied to corn and soybeans. After reviewing the 

data, the Sector decided to collect inspection data from across the country. An industry representative 

offered to assist with data analysis and along with the NIST representative will work in producing 

the inspection data needed for the analysis. A request for State participation will be sent to State 

weight and measures. The Sector requests that this remain a developing item as they move forward 

in evaluating additional data.

• North Carolina submitted the requested grain data for review.
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• Additional data is expected from other States participating in the grain data submission.

Table 3. Summary of Recommendations

Item GMA-19.1–D–Table T.2.1. Acceptance and Maintenance Tolerances Air Oven Method for 

All Grains and Oil Seeds.

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Grain Moister Meter Code 5.56 (a) as follows:

T.2.1. Air Oven Reference Method. – Maintenance and acceptance tolerances shall be as shown in 

Table T.2.1. Acceptance and Maintenance Tolerances Air Oven Reference Method. Tolerances are 

expressed as a fraction of the percent moisture content of the official grain sample, together with a 

minimum tolerance.

(Amended 2001)

Table T.2.1. 

Acceptance and Maintenance Tolerances Air Oven Reference Method

Type of Grain, Class, or 

Seed Tolerance Minimum Tolerance

Corn, oats, rice, sorghum, 

sunflower

0.05 of the percent

moisture content

0.8 %

in moisture content
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All other cereal grains and 

oil seeds

0.04 of the percent

moisture content

0.7 %

in moisture content

Table T.2.1. 

Acceptance and Maintenance Tolerances Air Oven Reference Method

for All Grains and Oil Seeds

Tolerance Minimum Tolerance

0.03 of the percent moisture content 0.5 % in moisture content

(Amended 2001 and 20XX) 

NIST OWM Detailed Technical Analysis: 

During the NTEP Grain Analyzer (GA) Sector 2019 meeting, the Sector reviewed data from Arkansas for 

Long Grain Rough Rice (LGRR) and other grains. The data showed that the proposal to tighten the 

acceptance and maintenance tolerance may not be appropriate for all grain types. The original data 

presented and used as a basis for the proposal applied to corn and soybeans. After reviewing the data, the 

Sector decided to collect inspection data from across the country. An industry representative offered to 

assist with data analysis and along with the NIST representative will work in producing the inspection data 

needed for the analysis. A request for State participation will be sent to State weight and measures. The 

Sector requests that this remain a developing item as they move forward in evaluating additional data. 

At the 2020 Interim Meeting the S&T Committee agreed to retain this item as developing in anticipation of 

additional data that is being collected to assess the proposed tolerances and the appropriateness of the 

change to tolerances for other grain types. The NIST Technical Advisor is working with the Grain Analyzer 

Sector and States to collect additional data on the proposed changes to the tolerances with plans to present 

data at the next NTEP GA Sector Meeting in August 2021. NIST OWM agrees with the S&T Committee 

that this item should be given a developing status until additional data is examined.

Ms. Diane Lee (NIST) is working with the Sector to collect data on Unified Grain Moisture Algorithm 

(UGMA) grain moisture meters and non-UGMA grain moisture meters North Carolina, Arizona, Illinois, 

and Iowa agreed to provide 2017-2019 inspection data on field meters. The participating States were 

requested to submit data by December 1, 2021. One state will be unable to participate and North Carolina

has submitted their data.

History

The GA Sector originally forwarded this proposal to the regional weights and measures associations with 

a proposed voting status. All regional weights and measures associations agreed to forward the proposal 

as a voting item on the 2019 NCWM Interim Agenda and the Sector appreciates their review and support. 

However, following the regional meetings additional data was submitted to the sector which indicates a 

need to consider developing different tolerance for some grain types. Through a subsequent ballot, and a 

majority vote, the sector agreed to recommend changing the status of the item to developing to provide the 

Sector time to consider additional data and changes to its original proposal. OWM agrees with the Grain 

Analyzer (GA) Sector’s revised decision to change the status of this item to “developing.”
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This proposal to change the air-oven method tolerances was developed during the 2018 GA Sector meeting. 

During the 2018 GA Sector Meeting, Dr. Charlie Hurburgh provided the Sector with an analysis of data for 

2-corn and 1-soybeans samples which included the average error for UGMA grain moisture meter 

technology and the average error of 2 MHz grain moisture meter technology from Iowa State weights and 

measures inspection data for years 2014-2017. Based on the Sectors review of the data, discussion of new 

tolerances, and the ability of the technologies to meet the new tolerances the Sector agreed to change the 

tolerances based on the data provided.

During additional discussion of what tolerances to apply to other grains, it was proposed that the same 

tolerances could apply to all grains, because corn is one of the more difficult grains to test and would likely 

have one of the largest variations when testing. No objections from States or meter manufacturers were 

provided during the discussion and voting to forward the item to the State regional weights and measures 

associations. Following the Sector meeting one State noted that there may be an issue with applying the 

tolerance to some grain types, specifically long grain rough rice. The GA Sector’s technical advisor 

requested that the State forward field data to review the grain moisture meter results for LGRR and other 

grains. After review of the data with the proposed tolerances it was determined that a high meter failure 

rate could result with a change to the tolerances for some grain types.

After the Sector’s Technical Advisor discussed the findings with the NTEP laboratory and the Sector 

members that originally proposed the tolerance change, they agreed with proposing a developing status for 

this item, the Sector was officially balloted and also agreed to change the originally proposed voting status 

to Developing to allow the Sector time to review additional data and make changes to its original proposal.

Summary of Discussions and Actions:

At the NCWM 2022 Interim Meeting, the Committee heard comments from Ms. Diane Lee (NIST OWM) 

who noted that additional data is needed to assess the proposed tolerances. Ms. Lee added that states would 

be submitting more data. Ms. Lee requested that this item remain Developing. During the Committee’s 

work session, the Committee agreed to a Developing status for this item.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Ms. Diane Lee (NIST OWM): This item has been on the agenda since 2019 - when it was proposed there 

was a study done on only corn and soybean samples (maybe we could lower the tolerances) subsequent to 

that, they received a report from a state to hold off to look at more data from different grain types (rough 

rice). Agreed to collect additional data, from a few additional states. A memo has gone out to participating 

states to collect more data on additional grains. They are in the process of collecting and hope to have a 

report in the interim on validity. Support as a Developing item.

The WWMA S&T Committee recommends the status remain developmental.
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Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the Committee heard no comments on this item. 

This Committee recommends this item remain Developing so that more data can be collected and presented 

in the future. 

Northeastern Weights and Measures Association

At the 2022 Interim Meeting Open Hearing, no comments were heard. The Committee recommends that 

this item remain in Developing Status.

At the 2022 Annual Meeting Open Hearing, Mrs. Tina Butcher (NIST OWM) commented on background 

for this item. There had been concerns if the current tolerances were too broad. The grain sector was 

looking into expanding the data set to include additional grains but there has been significant delay due to 

pandemic.

After hearing comments from the floor, the Committee recognized the need to further develop this item and 

recommended the item retain Developing status.

Central Weights and Measures Association 

During the 2022 Interim Meeting Open Hearing the Committee heard comments from the floor. Ms. Diane 

Lee (NIST OWM) is part of the sector. The sector met in August of this year and four States will be 

submitting data. Once data is collected, it will be given to the Grain Sector for them to decide what to with 

the item. Mr. Doug Musick (Kansas): are there old technology that can meet this requirement? Has any 

data been submitted regarding this?

CWMA S&T Committee recommends this item as Developing.

During the 2022 Annual Meeting Open Hearing, Mr. Doug Musick (Kansas) noted that some feel that rice 

will not be able to meet the tighter tolerance. Supports moving to voting. No data has been submitted 

regarding the concern, so they can do this at a later date if desired.

The CWMA S&T Committee recommends this moves forward as a Voting item.

MDM – MULTIPLE DIMENSION MEASURING DEVICES

MDM-22.1 D S.1.7. Minimum Measurement.

Source: Parceltool P/L

Purpose and Justification:

Exempt mobile tape based MDMD devices from the 12D minimum measurement.
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OWM Executive Summary for MDM-22.1 – S.1.7. Minimum Measurement.

OWM Recommendation: Unless additional information to justify the proposed changes to the MDMD 

Code is provided to the Committee by the submitter (or submitter’s consultant) on or before the 2022 

NCWM Annual Meeting, OWM recommends this item be withdrawn. 

• This is the identical proposal that appeared in the S&T Committee’s 2019 agenda (as S&T Item 

MDM-2) and was withdrawn by the Committee in 2019.

• The NCWM MDMD work group also reviewed the MDM-2 proposal during its spring 2019 meeting 

and recommended the item be withdrawn. 

• We have reviewed our comments and recommendations provided to the 2019 S&T Committee for 

S&T Item MDM-2 and still find them relevant today. Consequently, we provide them again with 

only few minor changes in our detailed analysis of this item included below. 

• There is no additional information provided in the justification section of this item in the Committee’s 

current agenda to explain the reason for resubmission or why the Committee should reconsider its 

earlier action to withdraw the item in 2019.

• We raised all of the above points during the 2022 NCWM Interim Meeting and recommended the 

Committee withdraw this item. During that same meeting, however, Mr. Darrell Flocken (NCWM) 

requested the Committee maintain a developing status based upon a request he had received from the 

submitter’s consultant who indicated the submitter wished to resurrect the item.

Table 3. Summary of Recommendations

MDM-22.1 S.1.7. Minimum Measurement.

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry • Letter from CubeTape 

(08-10-2021)

Manufacturers

Retailers and Consumers
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Table 3. Summary of Recommendations

MDM-22.1 S.1.7. Minimum Measurement.

V D W A I Notes* Comments

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Amend Handbook 44, Multiple Dimension Measuring Devices Code as follows:

S.1.7. Minimum Measurement. – Except for entries of tare and mobile tape based MDMD devices, 

the minimum measurement by a device is 12 d. The manufacturer may specify a longer minimum 

measurement. For multi-interval devices, this applies only to the first measuring range (or segment) of 

each measurement axis (length, width, and height).

(Amended 2017 and 20XX) 

NIST OWM Detailed Technical Analysis:

This very same proposal appeared in the S&T Committee’s 2019 agenda (as S&T Item MDM-2) and was 

withdrawn by the Committee in 2019. Additionally, the first two paragraphs included in the Committee’s 

current agenda beneath the heading “Original Justification,” are the very same two paragraphs contained in 

the Committee’s 2019 Interim Meeting Agenda in the Background Discussion section of the item. That is, 

there is no additional information provided in the justification section of this item in the Committee’s 

current agenda to explain the reason for resubmission or why the Committee should reconsider its earlier 

action to withdraw the item in 2019. OWM notes too that the NCWM MDMD work group also reviewed 

the MDM-2 proposal during its spring 2019 meeting and recommended the item be withdrawn. 

We have reviewed our comments and recommendations provided to the 2019 S&T Committee for S&T 

Item MDM2 and still find them relevant today. Consequently, we submit them again (shown in the box 

below to include a few minor changes that we’ve made) to the Committee as our analysis for the item 

“MDM-22.1” in the Committee’s current agenda.

OWM recognizes there is a potential for introducing excessive error in measurements when they are 

performed using a process or instrument that does not provide a sufficient level of resolution in the 

measurement. Minimum measurement requirements are established in NIST Handbook 44 device codes 

based on the premise, “rounding of digital values and the allowable error in a device from the application 

of tolerance creates the potential for large errors at small measurements.” This effect decreases 

proportionately as the measurement size is increased along with the number of increments used in the 

measurement. To put this principle into perspective as it relates to multiple dimension measuring devices 

(MDMDs), NIST Handbook 44 maintenance and acceptance tolerances applicable to MDMDs are plus or 

minus 1 division (See paragraph T.3. Tolerance Values). Considering this tolerance in perspective with 

this proposal, a 1-division error within a 12division measurement (i.e., the minimum measurement currently 

permitted in accordance with paragraph S.1.7.) represents over 8 percent of the measurement value (1 ÷ 12 
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= 0.083 ≃ 8.3 %). If the measurement were to include 50 divisions (or increments), that same 1-division 

error represents only 2 percent of the measurement value (1 ÷ 50 = 0.020 or 2 %).

Compounding the potential for even greater error is the fact that MDMDs are generally used to measure 

hexahedron-shaped objects by determining values for length, width, and height, and then multiplying these 

values together to determine the cubic volume occupied by the object. Since there are three measurements 

needed to determine the volume, the error effect of using a device to make small measurements is multiplied 

threefold. For example, a 1-division plus error at a 12-division measurement of length, width, and height 

would result in over a 27 percent error in the volume measurement of the object being measured as 

illustrated in the table below. 

Axis Measurement (+ 1 d error) Actual

Length 13 d 12 d

Width 13 d 12 d

Height 13 d 12 d

Volume 2197 x-unit3 1728 x-unit3

Difference:

Measurement minus Actual 

2197 x-unit3 – 1728 x-unit3 = 469 x-unit3

Percent error calculation (469 x-unit3 ÷ 1728 x-unit3

) x 100 = 27.1 %

Thus, given the potential that this proposal has for creating such very large measurement errors and the 

monetary impact those errors can have on commercial transactions, OWM does not believe this item should 

be advanced. 

In addition, OWM also points out the following concerns relating to this item:

• A guiding principle in the development of HB 44 requirements is that the same requirements should 

apply to devices used in the same application, regardless of technology or design. The proposed 

change in this item violates the principle by proposing there be an exemption to one of the 

requirements in the MDMD code for a particular type of MDMD.

• The background/discussion pertaining to this item includes the statement that it is not unusual for 

measurements to be made of less than 12 divisions. If this is in fact the case, those using these 

devices commercially to take such measurements are violating the minimum measurement 

requirement in HB 44. OWM would hope that the submitter of this item, knowing this to be true, 

would take necessary steps to educate users so that accurate measurements can be ensured. OWM 

believes that there may also be a problem caused by the use of a device with too large a division 

size for use in measuring small objects rendering that device unsuitable for the purpose intended. 

Another potential problem may be created when two devices with different division values are 

needed due to the wide linear range of the different axes needing to be measured. 

• The background/discussion portion of this item also indicates an accepted practice for this type of 

device is for the measurement to be rounded up to the nearest whole division. OWM notes such 

rounding conflicts with the instructions provided on the Federal Express and United States Postal 

Service websites for determining DIM weight, that specify the measurements are to be rounded to 

the nearest inch. 
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The current 12 d minimum measurement specified in HB 44 is uniform with the same in OIML R 129. 

Thus, a change to HB 44 requirement would cause conflict with OIML requirements.

OWM’s Comments and Recommendation for Item MDM-22.1 Copied from its 2019 Analysis of 

MDM-2

Summary of Discussions and Actions:

During Committee open hearings at the 2022 NCWM Interim Meeting, Mr. Rick Harshman (NIST OWM) 

reported this very same proposal had appeared in the S&T Committee’s 2019 agenda (as S&T Item MDM2) and was withdrawn by the Committee in 2019. Additionally, the first two paragraphs included in the 

Committee’s current agenda beneath the heading “Original Justification,” are the very same two paragraphs 

contained in the Committee’s 2019 Interim Meeting Agenda in the Background Discussion section of the 

item. That is, there is no additional information provided in the justification section of this item in the 

Committee’s current agenda to explain the reason for resubmission or why the Committee should reconsider 

its earlier action to withdraw the item in 2019. Mr. Harshman noted too that the NCWM MDMD work 

group also reviewed the MDM-2 proposal during its spring 2019 meeting and recommended the item be 

withdrawn. For these reasons, OWM recommends the item be withdrawn.

Mr. Darrell Flocken (NCWM) acknowledged he too was aware that the proposal is identical to the one that 

the Committee had withdrawn in 2019. He noted, however, that he had been contacted by a representative 

of the submitter and that this person had advised him the submitter desired to further pursue adoption of the 

proposal. Mr. Flocken indicated he expected new information to be made available to Committee from the 

submitter to provide better justification for it. 

During the Committee’s work session members of the Committee agreed to maintain the item on the 

Committee’s agenda as a Developing item to allow the submitter an opportunity to provide additional 

information that could justify the proposed changes. 

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Russell Vires (Mettler Toledo): Mettler is opposed to the change proposed here. No reason to eliminate 

the minimum measurement.

The WWMA S&T Committee recommends that this item be assigned a Developmental status. The 

Committee recommends that the submitter provide data to support why the devices are unable to meet the 

12-division requirement. The Committee also recommends that the submitter consult the MDMD working 

group.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Russ Vires (Mettler Toledo) requested that this item 

be withdrawn because the justification was invalid. 
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This Committee recommends this item be Withdrawn due to having no justification provided for the 

change. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Rick Harshman (NIST OWM) commented that this is a new item and members of NIST OWM’s LMDP 

have not had opportunity to review/consider it. There’s little information provided in the 

background/discussion of this item. If the device has digital indication, by rounding all values up as is 

specified in the background/discussion, the device would fail to comply with HB 44 paragraph GS.5.2.2.(c). 

Mr. Lou Sakin (Hopkinton/Northbridge, Massachusetts) commented that this item is in-need of further 

development. 

The NEWMA Specifications and Tolerances Committee recommends that this item be given Developing 

Status. 

During the 2022 Annual Meeting Open Hearings the following comments were heard:

Mr. Russ Vires (SMA) rose to oppose the item. He commented that the justification provided by the 

submitter does not identify issue that is to be resolved. Mr. Vires suggested that the submitter work with 

MDM Workgroup for a solution and referenced the workgroup meets in May and will be discussing this 

proposal.

After hearing comments from the floor, the Committee recognized the need to further develop this item and 

recommended the item retain Developing status.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard no comments from the floor. 

CWMA S&T Committee has no recommendation for this item.

During the 2022 Annual Meeting Open Hearings, the Committee received the following comments:

Mr. Russ Vires (SMA) - The SMA opposes this item. The justification provided by the submitter does not 

adequately identify the issue this item is attempting to resolve, and why mobile tape-based MDMD devices 

should be exempted compared to all other MDMD devices. The SMA recommends that the submitter work 

with the MDMD Workgroup to develop a suitable solution to this issue.

The CWMA S&T Committee recommends this item to be withdrawn.

SMA 

During the 2021 Fall Meeting the SMA opposed this item. The justification provided by the submitter does 

not adequately identify the issue this item is attempting to resolve, and why mobile tape-based MDMD 

devices should be exempted compared to other MDMD devices. The SMA recommends that the submitter 

work with the MDMD Workgroup to develop a suitable solution to this issue.
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During the 2022 Spring Meeting the SMA opposed this item.

Rationale: The justification provided by the submitter does not adequately identify the issue this item is 

attempting to resolve, and why mobile tape-based MDMD devices should be exempted compared to all 

other MDMD devices. The SMA recommends that the submitter work with the MDMD Workgroup to 

develop a suitable solution to this issue.

OTH – OTHER ITEMS

OTH-16.1 D Electric Watthour Meters Code under Development

Source: NIST Office of Weights and Measures

Purpose and Justification:

1) Make the weights and measures community aware of work being done within the NIST U.S. 

National Work Group (USNWG) on Electric Vehicle Fueling and Submetering to develop proposed 

requirements for electric watthour meters used in submeter applications in residences and 

businesses;

2) Encourage participation in this work by interested regulatory officials, manufacturers, and users of 

electric submeters.

3) Allow an opportunity for the USNWG to provide regular updates to the S&T Committee and the 

weights and measures community on the progress of this work;

4) Allow the USWNG to vet specific proposals as input is needed.

OWM Executive Summary for OTH-16.1 Electric Watthour Meters Code Under 

Development

OWM Recommendation: OWM recommends this item be retained on the Committee’s agenda as a 

Developing item while the USNWG EVF&S EWH Subgroup finalizes a draft code for submission in the 

2023 standards development cycle.

• The USNWG on Electric Vehicle Fueling & Submetering Electric Watthour Meter Subgroup (EWH 

SG) is charged with developing standards and test procedures utility-type watt hour meters.

• The SG has been developing a draft code for inclusion in NIST Handbook 44 and submitted an early 

draft in September 2021.

o The draft was posted on the S&T Committee’s web site for review and comment with a request 

for comments by March 2022 to allow the SG to address concerns prior to finalizing the code for 

submission.

• The SG only received comments from CA DMS at the Fall 2021 WWMA meeting and again from 

the 2022 NCWM Interim Meeting supporting further development of this item. California concerns 

include:
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OWM Executive Summary for OTH-16.1 Electric Watthour Meters Code Under 

Development

o identity marking requirements being on a separate document to satisfy model and serial 

number prefixes;

o the current lack of clarification on what constitutes a separate document;

o electronic versions of this information do not originate from the system;

o testing capabilities should be easily and readily achievable before and after the installation 

to facilitate the resolution of accuracy complaints;

o An additional observation is that the method of sealing for category II and III devices 

requires a hard copy of audit trail and event logger information whereas codes are 

considering the allowance of electronic forms of this information.

• The S&T Committee agreed to include this item as a Developing Item on its agenda to keep the 

weights and measures community informed of progress and facilitate participation by interested 

parties.

o Mrs. Tina Butcher (NIST OWM) has provided regular updates to the NCWM and regional 

weights and measures association S&T Committees on this work. Details are found in past 

Committee reports.

• In the Fall 2021 and Spring 2022 all of the regional weights and measures associations have 

recommended maintaining this item as a Developing item on the Committee’s agenda as the SG 

finalizes its draft.

• The SG continues work on the draft; it held eighteen meetings in 2021 and seven meetings thus far 

in 2022.

• The SG still hopes to resolve the remaining issues regarding the draft code and submit a draft to the 

NCWM S&T for consideration in the 2022-2023 NCWM cycle under this agenda item, and asks the 

Committee to maintain this item as Developing on its agenda to facilitate this submission.

Table 3. Summary of Recommendations

OTH-16.1 Electric Watthour Meters Code under Development

V D W A I Notes* Comments

Submitter 

 • Initial Draft Code for Non-Utility

Electricity-Measuring Systems (09-01-

2021)

OWM 

WWMA 

SWMA 
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Table 3. Summary of Recommendations

OTH-16.1 Electric Watthour Meters Code under Development

V D W A I Notes* Comments

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration: 

This item was added to the NCWM S&T Committee’s agenda as a “Developing Item” to allow a forum in 

which progress of the USNWG can be reported as it develops legal metrology requirements for electric 

watthour meters and continues work to develop test procedures and test equipment standards.

Mrs. Tina Butcher (NIST OWM), Chair of the USNWG on Electric Refueling & Submetering, has 

continued to provide regular updates to the Committee on this work and to encourage input and participation 

from the weights and measures community since the addition of this item to the Committee’s agenda in 

2016. See the Committee’s 2016 through 2021 Final Reports and 2022 Interim Report for details.

The SG is nearing completion of a draft NIST Handbook code for “Non-Utility Electricity-Measuring 

Systems.” Work continues on a few sections of the draft code; however, the SG would like to begin getting 

feedback from the weights and measures community on the draft code. The SG requested that the 

Committee post an early draft of the code on the NCWM website. 

The draft code was posted in Fall 2021 and is available for download at 

https://www.ncwm.com/publication-15. 

The Subgroup asks the NCWM S&T Committee to consider (and the regional associations to support) the 

following.

1. Permitting the item to remain in a Developing status on its agenda to allow for further development 

and input on the draft Handbook 44 Code.
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2. Permitting the SG to post the draft code along with other supporting documents on the NCWM 

S&T Committee’s web page. Areas under review and development by the SG will be noted in 

yellow highlighted text.

3. Encouraging weights and measures officials and industry to study the draft code and provide input 

to the SG, including proposed changes along with rationale for such changes and any indication of 

support or opposition.

The SG requested comments be submitted to the SG Chair or Technical Advisor by the end of March 2022. 

The above approach was intended to allow the SG the opportunity to solicit input and incorporate comments 

from the weights and measures community on the draft code in advance of proposing it for a vote more 

broadly.

The SG has continued to meet and revise specific areas of the code and still hopes to finalize a draft for 

submission in the 2022-2023 NCWM cycle.

The Electric Watthour Meter Subgroup (EWH SG) of the USNWG on Electric Vehicle Fueling & 

Submetering has held multiple in-person and web meetings since the 2017 NCWM Annual Meeting. This 

SG has held 15 virtual meetings since January 2021 focused on finalizing a draft code on “Non-Utility 

Electricity-Measuring Systems.”

Those interested in participating in this work are asked to contact SG Chair, Ms. Lisa Warfield, or Technical 

Advisor, Mrs. Tina Butcher. Contact information is included in the “Background” section of this item.

NIST OWM Detailed Technical Analysis: 

• The USNWG on Electric Vehicle Fueling & Submetering Electric Watthour Meter Subgroup (EWH 

SG) is charged with developing standards and test procedures utility-type watt hour meters.

• The SG developed a proposed addition to NIST Handbook 130’s Uniform Regulation for the Method 

of Sale (MOS) of Commodities specifying a method of sale for electrical energy sold through these 

systems; “Section 2.38. Non-Utility Transactions of Electrical Energy (Other than Vehicle Fueling 

Applications)” was adopted by the NCWM in July 2019.

• The SG has been developing a draft code for inclusion in NIST Handbook 44 and submitted an early 

draft in September 2021 which was posted on the NCWM’s web site for review and comment.

o The SG requested comments by March 2022 to allow the SG to address any concerns in its 

final recommendations for a draft code.

• The SG received comments from California DMS through the Fall 2021 WWMA meeting and again 

from the 2022 NCWM Interim Meeting supporting further development of this item. California

expressed concerns about identity marking requirements being on a separate document to satisfy model 

and serial number prefixes, noting the current draft does not clarify what constitutes a separate 

document (other than specifying a “hard” or “electronic” form) and does not originate from the system. 

California strongly feels testing capabilities should be easily and readily achievable before and after 

the installation as well as means for verifying validity of complaints based on inaccuracy. An additional 

observation is that, as written, the method of sealing for category II and III devices requires a hard copy 
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of audit trail and event logger information; however, other codes are being considered to allow 

electronic forms of this information.

o No other comments have been received.

• Mrs. Tina Butcher (NIST OWM) has provided regular updates to the NCWM and regional weights and 

measures association S&T Committees on this work. Details are found in past Committee reports.

• In September 2021, Mrs. Butcher submitted a request to NCWM S&T Committee Chair, Mr. Brad 

Bachelder to:

1. Permit the item to remain in a Developing status on its agenda to allow for further development 

and input on the draft NIST Handbook 44 Code.

2. Permit the SG to post the draft code along with other supporting documents on the NCWM S&T 

Committee’s web page. Areas under review and development by the SG are noted in highlighted 

text.

3. Encourage weights and measures officials and industry to study the draft code and provide input to 

the SG, including proposed changes along with rationale for such changes and any indication of 

support or opposition.

• Chair Bachelder agreed to post a draft of the code on the NCWM S&T Committee’s web site.

• The SG requests this item maintain a Developing status.

o In their Fall 2021 meetings, all four regional weights and measures associations supported 

maintaining this item as a Developing item on the Committee’s agenda as did the CWMA and 

NEWMA at their Spring 2022 annual meetings.

• The S&T Committee agreed to include this item as a Developing Item on its agenda to keep the weights 

and measures community informed of progress and facilitate participation by interested parties.

• Work continues on some sections of the draft code.

• The SG held eighteen meetings in 2021 (February 3; February 4; February 22; March 11; March 25; 

April 19; April 26; May 26; June 2; June 16; June 24; July 12; July 13; August 23; August 24; 

November 2; November 16; November 18) and seven meetings thus far in 2022 (February 1, February 

17, March 1, April 4, April 13, April 20, May 18, in addition to meetings of small Task Groups focused 

on specific issues.

• The SG still hopes to resolve the remaining issues regarding the draft code and submit a draft to the 

NCWM S&T for consideration in the 2022-2023 NCWM cycle under this agenda item.

• Those interested in participating in this work please contact:

o Subgroup Chair, Ms. Lisa Warfield (NIST OWM)

Email (lisa.warfield@nist.gov) or phone (301-975-3308)
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o Technical Advisor, Mrs. Tina Butcher (NIST OWM)

Email (tbutcher@nist.gov) or phone (301-975-2196)

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting

Mr. Matt Douglas (California – DMS) stated that California supports the development of this item but has 

concerns about identity marking requirements being on a separate document. Also, the devices should be 

easy to test before and after instillation. This device should allow for electronic data logger. Ms. Juana 

Williams (NIST OWM) commented that the subgroup had provided a draft code that is on the website. Ms. 

Williams requested comments be submitted to Mrs. Tina Butcher (NIST OWM) or Ms. Lisa Warfield 

(NIST OWM) by March 22, 2022. Ms. Williams stated these comments will be used to provide and 

updated draft for the 2022-2023 submission cycle and the item remain in developing status. The Committee 

agreed that the item be given a Developing status.

Regional Association Reporting: 

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Matt Douglas (California - DMS): California supports further development of this item. Concerns 

about the identity marking information which allows a separate document to satisfy model and seral number 

prefixes and doesn’t clarify what constitutes a separate document other than hard or electronic and does not 

originate from the system. We strongly feel that testing capabilities should be easily and readily achievable 

before and after the installation as well as means for verifying validity of complaints based on inaccuracy. 

An observation – as written the method of sealing category II and III requires a hard copy of audit trail and 

event logger information. Other codes are being considered to allow electronic forms of this information. 

The WWMA S&T Committee recommends this item remain in a Developing status. The Committee 

acknowledged that, as referenced in the Committee’s agenda, the submitter of the item has asked the item 

to remain in a Developing status to allow for further refinement and input on the draft NIST HB 44 code. 

Based upon this information and the comments received during its open hearings, the Committee 

encourages the NIST USNWG Subgroup to consider the comments provided by CA DMS at the WWMA 

meeting. The Committee also encourages others in the weights and measures community to continue 

studying the draft code and provide input to the Subgroup as requested in the agenda item.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the Committee heard no comments on this item. 

This Committee recommends this item remain Developing so that more work can continue at the request 

of the submitter. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.
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Ms. Juana Williams (NIST OWM) commented below and recommended developing status.

• NIST OWM notes that the USNWG Subgroup on Watthour-Type Electric (EWH) Meters is nearing 

completion of its proposed tentative code for utility-type watthour submeters. 

• As noted in the agenda, there are a few sections of the draft code that require additional work by the 

EWH Subgroup.

o NIST OWM asks that the item remain in a Developing status while the Subgroup completes 

these remaining items.

• The Subgroup is asking for feedback on the remaining portions of the draft code thus far.

o The NCWM S&T Committee has agreed to post the draft on the S&T’s website to allow for 

broader review and comment.

o NIST OWM encourages review and input on the draft.

o This input will allow the Subgroup to begin incorporating feedback from the community and 

better prepare the draft for submission in the 2022-2023 cycle.

The NEWMA Specifications and Tolerances Committee recommends that this item be given Developing 

Status. 

At the 2022 NEWMA Annual Meeting, NEWMA heard from Mrs. Tina Butcher (NIST OWM) who 

commented that this item pertains to electric submeters. The Subgroup is still working on the proposal and 

has prepared a draft; however, three or four items need to be resolved with regard to criteria for marking 

and testing.

After hearing comments from the floor, the Committee recognized the need to further develop this item and 

recommended the item retain developing status.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mrs. Tina 

Butcher (NIST OWM) noted the item has been on the agenda for five years. Needs a little more work from 

subcommittee. She recommended item as developing and would like public comments. 

The CWMA S&T Committee recommends the item as a developing item.

At the 2022 CWMA Annual Meeting, the CWMA heard from Ms. Lisa Warfield (NIST OWM) who 

reported that an extensive group of industry and regulators are working to understand each other’s roles as 

this code develops. The NIST work group is quite active and making progress. The CWMA S&T 

Committee recommends this item to remain as Developing.

OTH-22.1 D Appendix A: Fundamental Considerations, 3. Testing Apparatus

This item was modified and combined with Item GEN-19.1 and resides in Block 8.
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OTH-22.2 V Appendix D – Definitions: face

Source: NIST Office of Weights and Measures

Purpose and Justification:

To correct the apparent oversight of not referencing the codes that clearly make use of the term “face”; 

include the missing code section numerical designations of 3.32, 3.37, and 3.39 in the [brackets] following 

the second meaning definition of the term “face” in NIST Handbook 44 Appendix D. The inclusion of 

those specific device code designations will clarify the term is applicable to retail devices addressed in the 

LPG and Anhydrous Ammonia Liquid-Measuring Devices, Mass Flow Meters (MFM), and Hydrogen GasMeasuring Devices Codes, respectively. The term has special meaning for these types of systems because 

the “face” of these retail devices is specified as the only permissible location for specific quantity, pricing, 

and related marking information that provide clarity about the correct computation of each sale by the 

dispensing system. 

OWM Executive Summary for Appendix D – Definitions: face

OWM Recommendation: OWM believes this item is fully developed and ready for a vote. This 

item corrects an oversight that was made when the term was originally added to NIST Handbook 44 

and helps ensure consistency in the application of the term across multiple codes.

• This proposal corrects the inadvertent omission of multiple numerical code designations from the 

definition of “face” where this unique term is cited in those code’s design and user requirements.

• Including the added reference in the definition to the missing three codes sections ensures the 

manufacturers of these devices has information for the proper placement of transaction 

information in use by both the buyer and seller and necessary to the regulatory official.

• The current definition of “face” remains broad enough to recognize both customary transaction 

information as well as the more recent use of nontraditional application-specific information.

Table 3. Summary of Recommendations

OTH-22.2 Appendix D – Definitions: face

V D W A I Notes* Comments

Submitter 

 See “Supporting Information from NIST” 

dated 8/12/21.

OWM 

WWMA 

SWMA 

NEWMA 5

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes
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Table 3. Summary of Recommendations

OTH-22.2 Appendix D – Definitions: face

V D W A I Notes* Comments

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

Modify the definition for “face” in Appendix D definitions as follows:

face. – That portion of a computing-type pump or dispenser which displays the actual computation of 

price per unit, delivered quantity, and total sale price. In the case of some electronic displays, this may 

not be an integral part of the pump or dispenser. [3.30, 3.32, 3.37, and 3.39] 

(Added 1987) (Amended 2022)

NIST OWM Detailed Technical Analysis:

This proposal is a housekeeping item intended to correct the omission of multiple numerical designations 

of applicable code sections from the NIST HB 44 Appendix D definition of the term “face.” Those codes’ 

numerical designations should have appeared in the definition at the same time as the term “face” was first 

recognized in each codes’ display and posting requirements. 

The consistent and proper placement of specific transaction information on the “face” of the dispenser 

ensures clear and easy access, selection, and use of that information throughout the entire sale by both the 

buyer and seller. The appearance of references to those code designations in the definition of the term 

“face” also benefit the manufacturer designing the device. 

The proposal expands the handbook codes referenced in the definition of “face” from one to four sections. 

The 15 relevant handbook code paragraphs that include requirements for specific information to be either 

indicated, displayed, posted, or automatically shown on the “face” of device types in addition to retail liquid 

measuring devices (i.e., code section 3.30) are specified in Code Sections:

(1) 3.32 LPG and NH3 Liquid-Measuring Devices 

(2) 3.37 MFM Code, and 

(3) 3.39 Hydrogen Gas-Measuring Devices 

The wording of the current definition may seem a bit archaic; however, its scope remains broad enough to 

recognize both customary transaction information as well as the more recent use of nontraditional 
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application-specific computational information such as supplemental fuel conversion units or instances 

where there is the option for use of either a built-in or remote primary display.

Summary of Discussions and Actions:

NCWM 2022 Interim Meeting

Based on no comments in opposition and the submitter’s request for voting status, the committee 

recommends that this item be voted on at the annual meeting.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Matt Douglas (California - DMS) : This item seems to be housekeeping. CA DMS supports this code.

The WWMA S&T Committee recommends that this item be assigned a Voting status. The Committee 

agrees that this item has merit and is fully developed.

Southern Weights and Measures Association

At the 2021 Annual Meeting Open Hearing, the SWMA S&T committee heard no comments on this item. 

The SWMA recommends moving this forward as a Voting item.

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Ms. Juana Williams (NIST OWM) commented that this is a housekeeping item and recommends moving 

forward as a Voting item. 

Mr. Jim Willis (New York) also supports giving this item Voting status.

The NEWMA Specifications and Tolerances Committee recommends that this item be moved forward with 

a Voting Status.

During the 2022 Annual Meeting Open Hearing no comments were heard on this item. NEWMA makes 

no recommendation to the NCWM.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the committee heard comments from the floor. Mrs. Tina 

Butcher (NIST) stated this item is cleaned up and ready to move forward as a Voting item.

CWMA S&T Committee recommends this item move forward as a Voting item.
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During the 2022 Annual Meeting Open Hearing no comments were heard from the floor.

The CWMA S&T Committee recommends this moves forward as a Voting item. CWMA recommends this 

item proposal as a Voting Item on the NCWM agenda. 

ITEM BLOCK 1 (B1) W TERMINOLOGY FOR TESTING STANDARDS

(original B1 items)

B1: SCL-18.1 W N.2. Verification (Testing) Standards 

B1: ABW-18.1 W N.2. Verification (Testing) Standards 

B1: AWS-18.1 W N.1.3. Verification (Testing) Standards, N.3.1. Official Tests, UR.4. Testing 

Standards 

B1: CLM-18.1 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards

B1: CDL-18.1 W N.3.2. Transfer Standard Test, T.3. On Tests Using Transfer Standards

B1: HGM-18.1 W N.4.1. Master Meter (Transfer) Standard Test, T.4. Tolerance Application on Test 

Using Transfer Standard Test Method

B1: GMM-18.1 W 5.56(a): N.1.1. Air Oven Reference Method Transfer Standards, N.1.3. Meter to 

Like-Type Meter Method Transfer Standards and 5.56(b): N.1.1. Transfer 

Standards, T. Tolerances1

B1: LVS-18.1 W N.2. Testing Standards

B1: OTH-18.1 W Appendix A: Fundamental Considerations, 3.2. Tolerances for Standards, 3.3. 

Accuracy of Standards

B1: OTH-18.2 W Appendix D – Definitions: fifth-wheel, official grain samples, transfer standard 

and Standard, Field

(Note: During the 2019 NCWM Interim Meeting, the S&T Committee considered comments during 

Opening Hearings and recommended that the following Items appearing on the 2019 Agenda as GEN-3, 

B1, B2, LPG-3 and MFM-5 be combined and gave these items an Assigned status. Item Block 1 included

previously numbered items: GEN-3; Block 1; Block 2; LPG-3; and MFM-5. 

Note: Based on comment heard during the 2021 Annual Meeting, the S&T Committee recommended that 

all items that were combined with Block 1 “Terminology For Testing Standards” and originally appeared 

as a separate item or separate block of items on the S&T agenda prior to 2019, be removed from Block 1 

and appear as originally presented. As such, the items presented in this block are the original items included 

in Block 1 “Terminology For Testing Standards”.)

Source: NIST Office of Weights and Measures

Purpose and Justification:

To remove the current limited definition and use of the term “Transfer Standard” and eliminate terms 

“Testing Standards”, “Verification (Testing) Standards”, and instead use the term Field Standard, consistent 

with its reference in Handbook 44, Appendix A, Fundamental Considerations and its use in several sections 

of Handbook 44. To correct the broad use of the term Transfer Standard and instead replace its use with 

the term Field Standard. To update all use of the term “standard” to use the term “Field Standard”. To 

remove the current limited definition of Transfer Standard and instead use the term Field Standard. 
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Table 3. Summary of Recommendations

Item Block 1 (B1) Terminology for Testing Standards

V D W A I Notes Comments 

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 5 This item was not discussed because it was 

withdrawn at the 2022 Interim Meeting.

CWMA 5 This item was not considered because it was 

withdrawn at the 2022 Interim Meeting.

NCWM 

Letters of Support Letters of Opposition Notes

Industry

• Comments from Seraphin 

(06-29-2018) 

• Comments from Seraphin 

(07-31-2018) 

• Comments from Ross 

Andersen (12-12-2018)

• Comments from Weights 

and Measures Consulting 

and Seraphin Test Measure 

Co. (01-13-2021)

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered 

OWM Executive Summary for Item Block 1 (B1) Terminology for Testing Standards

OWM Recommendation: The submitter, NIST OWM withdrew this item at the 2022 Interim Meeting. 

NIST OWM worked with Seraphin on Block 8 items which includes proposed definitions for Standards 

in NIST HB 44 and these terms and definitions are proposed and being considered. 
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Item Under Consideration

B1: SCL-18.1 W N.2. Verification (Testing) Standards

Amend Handbook 44, Scales Code as follows:

N.2. Verification (Testing) Field Standards. – Field standard weights used in verifying weighing 

devices shall comply with requirements of NIST Handbook 105-Series standards (or other suitable and 

designated standards) or the tolerances expressed in Fundamental Considerations, paragraph 3.2. (i.e., 

one-third of the smallest tolerance applied). 

(Amended 1986 and 20XX) 

B1: ABW-18.1 W N.2. Verification (Testing) Standards

Amend Handbook 44, Automatic Bulk Weighing Systems Code as follows:

N.2. Verification (Testing) Field Standards. – Field Sstandard weights and masses used in verifying 

weighing devices shall comply with requirements of NIST Handbook 105-1 (Class F) or the tolerances 

expressed in Appendix A, Fundamental Considerations, paragraph 3.2. (i.e., one-third of the smallest 

tolerance applied). 

(Amended 20XX)

B1: AWS-18.1 W N.1.3. Verification (Testing) Standards, N.3.1. Official Tests, UR.4. Testing 

Standards

Amend Handbook 44, Automatic Weighing Systems Code as follows:

N.1.3. Verification (Testing) Field Standards. – Field standard weights shall comply with 

requirements of NIST Handbook 105-1, “Specifications and Tolerances for Field Standard Weights 

(Class F)” or the tolerances expressed in Fundamental Considerations, paragraph 3.2. (i.e., one-third of 

the smallest tolerance applied). 

(Amended 20XX)

N.3.1. Official Tests. – Officials are encouraged to periodically witness the required “in house” 

verification of accuracy. Officials may also conduct official tests using the on-site testing field

standards or other appropriate standards belonging to the jurisdiction with statutory authority over the 

device or system.

(Amended 20XX)

UR.4. Testing Field Standards. – The user of a commercial device shall make available to the official 

with statutory authority over the device testing field standards that meet the tolerance expressed in 

Fundamental Considerations, paragraph 3.2. Tolerances for Standards (i.e., one-third of the smallest 

tolerance applied). The accuracy of the testing field standards shall be verified annually or on a 

frequency as required by the official with statutory authority and shall be traceable to the appropriate 

SI standard.

(Amended 20XX)
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B1: CLM-18.1 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards

Amend Handbook 44, Cryogenic Liquid-Measuring Devices Code as follows:

N.3.2. Transfer Field Standard Test. – When comparing a meter with a calibrated transfer field

standard, the test draft shall be equal to at least the amount delivered by the device in two minutes at 

its maximum discharge rate, and shall in no case be less than 180 L (50 gal) or equivalent thereof. When 

testing uncompensated volumetric meters in a continuous recycle mode, appropriate corrections shall 

be applied if product conditions are abnormally affected by this test mode. 

(Amended 1976 and 20XX) 

T.3. On Tests Using Transfer Standards. – To the basic tolerance values that would otherwise be 

applied, there shall be added an amount equal to two times the standard deviation of the 

applicable transfer standard when compared to a basic reference standard. (Added 1976)

B1: CDL-18.1 W N.3.2. Transfer Standard Test, T.3. On Tests Using Transfer Standards

Amend Handbook 44, Carbon Dioxide Liquid-Measuring Devices Code as follows:

N.3.2. Transfer Field Standard Test. – When comparing a meter with a calibrated transfer field

standard, the test draft shall be equal to at least the amount delivered by the device in two minutes at 

its maximum discharge rate.

(Amended 20XX)

T.3. On Tests Using Transfer Standards. – To the basic tolerance values that would otherwise be 

applied, there shall be added an amount equal to two times the standard deviation of the 

applicable transfer standard when compared to a basic reference standard.

B1: HGM-18.1 W N.4.1. Master Meter (Transfer) Standard Test, T.4. Tolerance Application on 

Test Using Transfer Standard Test Method

Amend Handbook 44, Hydrogen Gas-Measuring Devices Tentative Code as follows:

N.4.1. Master Meter (Transfer) Field Standard Test. – When comparing a measuring system with a 

calibrated transfer field standard, the minimum test shall be one test draft at the declared minimum 

measured quantity and one test draft at approximately ten times the minimum measured quantity or 1 

kg, whichever is greater. More tests may be performed over the range of normal quantities dispensed.

(Amended 20XX)

T.4. Tolerance Application on Test Using Transfer Standard Test Method. – To the basic 

tolerance values that would otherwise be applied, there shall be added an amount equal to two 

times the standard deviation of the applicable transfer standard when compared to a basic 

reference standard.
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B1: GMA-18.1 W 5.56(a): N.1.1. Air Oven Reference Method Transfer Standards, N.1.3. Meter 

to Like-Type Meter Method Transfer Standards and 5.56(b): N.1.1. Transfer 

Standards, T. Tolerances1

Amend Handbook 44, Grain Moisture Meters Code as follows:

5.56.(a) Grain Moisture Meters

N.1.1. Air Oven Reference Method Transfer Field Standards. – Official grain samples shall be used 

as the official transfer field standards with moisture content and test weight per bushel values assigned 

by the reference methods. The reference methods for moisture shall be the oven drying methods as 

specified by the USDA GIPSA. The test weight per bushel value assigned to a test weight transfer 

standard shall be the average of 10 test weight per bushel determinations using the quart kettle test 

weight per bushel apparatus as specified by the USDA GIPSA. Tolerances shall be applied to the 

average of at least three measurements on each official grain sample. Official grain samples shall be 

clean and naturally moist, but not tempered (i.e., water not added).

(Amended 1992, 2001, and 2003, and 20XX) 

N.1.3. Meter to Like-Type Meter Method Transfer Standards. – Properly standardized reference 

meters using National Type Evaluation Program approved calibrations shall be used as transfer field

standards. A reference meter shall be of the same type as the meter under test. Tests shall be conducted 

side-by-side using, as a comparison medium, grain samples that are clean and naturally moist, but not 

tempered (i.e., water not added). 

(Added 2001) (Amended 20XX)

5.56.(b) Grain Moisture Meters

N.1.1. Transfer Field Standards. – Official grain samples shall be used as the official transfer field

standards with moisture content values assigned by the reference methods. The reference methods shall 

be the oven drying methods as specified by the USDA GIPSA. Tolerances shall be applied to the 

average of at least three measurements on each official grain sample. Official grain samples shall be 

clean and naturally moist, but not tempered (i.e., water not added). 

(Amended 1992 and 20XX) 

T. Tolerances1

1

These tolerances do not apply to tests in which grain moisture meters are the transfer field standards.

(Amended 20XX)

B1: LVS-18.1 W N.2. Testing Standards

Amend Handbook 44, Electronic Livestock, Meat and Poultry Evaluation Systems and/or Devices Code as 

follows:

N.2. Testing Field Standards. – ASTM Standard F2343 requires device or system users to maintain 

accurate reference field standards that meet the tolerance expressed in NIST Handbook 44 Fundamental 

Considerations, paragraph 3.2. Tolerances for Standards (i.e., one-third of the smallest tolerance applied).

(Amended 20XX)
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B1: OTH-18.1 W Appendix A: Fundamental Considerations, 3.2. Tolerances for Standards, 3.3. 

Accuracy of Standards

Amend Handbook 44, Appendix A: Fundamental Considerations as follows:

3.2. Tolerances for Field Standards. – Except for work of relatively high precision, it is 

recommended that the accuracy of standards used in testing commercial weighing and measuring 

equipment be established and maintained so that the use of corrections is not necessary. When the 

standard is used without correction, its combined error and uncertainty must be less than one-third of 

the applicable device tolerance.

Device testing is complicated to some degree when corrections to standards are applied. When using 

a correction for a standard, the uncertainty associated with the corrected value must be less than onethird of the applicable device tolerance. The reason for this requirement is to give the device being 

tested as nearly as practicable the full benefit of its own tolerance.

(Amended 20XX) 

3.3. Accuracy of Field Standards. – Prior to the official use of testing apparatus, its accuracy should 

invariably be verified. Field standards should be calibrated as often as circumstances require. By their 

nature, metal volumetric field standards are more susceptible to damage in handling than are standards 

of some other types. A field standard should be calibrated whenever damage is known or suspected to 

have occurred or significant repairs have been made. In addition, field standards, particularly 

volumetric standards, should be calibrated with sufficient frequency to affirm their continued accuracy, 

so that the official may always be in an unassailable position with respect to the accuracy of his testing 

apparatus. Secondary field standards, such as special fabric testing tapes, should be verified much more 

frequently than such basic standards as steel tapes or volumetric provers to demonstrate their constancy 

of value or performance.

Accurate and dependable results cannot be obtained with faulty or inadequate field standards. If either 

the service person or official is poorly equipped, their results cannot be expected to check consistently. 

Disagreements can be avoided, and the servicing of commercial equipment can be expedited and 

improved if service persons and officials give equal attention to the adequacy and maintenance of their 

testing

(Amended 20XX)

B1: OTH-18.2 W Appendix D – Definitions: fifth-wheel, official grain samples, transfer 

standard and Standard, Field

Amend Handbook 44, Appendix A: Fundamental Considerations as follows:

fifth wheel. – A commercially-available distance-measuring device which, after calibration, is 

recommended for use as a field transfer standard for testing the accuracy of taximeters and odometers on 

rented vehicles. [5.53, 5.54]

(Amended 20XX)

official grain samples. – Grain or seed used by the official as the official transfer field standard from the 

reference standard method to test the accuracy and precision of grain moisture meters. [5.56(a), 5.56(b)]

(Amended 20XX)
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transfer standard. – A measurement system designed for use in proving and testing cryogenic liquidmeasuring devices. [3.38]

Standard, Field. – A physical standard that meets specifications and tolerances in NIST Handbook 

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. 

(Added 20XX)

NIST OWM Detailed Technical Analysis: 

Seraphin and NIST OWM worked on revisions to GEN-19.1 and OTH-22.1 which is now Block 8. The 

definitions and terminology proposed in Block 8 are in conflict with the terminology in Block 1. As such, 

NIST OWM recommends the withdraw of Block 1 items. NIST OWM may revisit its work with Seraphin 

to develop revisions to Block 1 Terminology that would agree with Block 8 currently on the 2022 S&T 

Interim Meeting agenda, at a later date.

Summary of Discussions and Actions:

The term transfer standard is currently defined in HB 44 as only being applicable to the Cryogenic Liquid 

Measuring Devices Code. This definition should be removed as it is very limited in scope and the item 

termed a ‘transfer standard’ is in fact a robust working measurement standard used in field conditions, better 

termed and shortened to Field Standard. All instruments/devices used as a Field Standard in the testing of 

Weighing and Measuring Devices, regardless of nomenclature, must comply with the requirements of HB 

44, Appendix A, Fundamental Considerations Associated with the Enforcement of Handbook 44 Codes, 

paragraph 3.2 Testing Apparatus, Adequacy. Using the term transfer standard as it is recently being applied 

in no way negates this requirement of adequacy and confuses the user as to the nature of the field standard 

being used.

Use of the single word ‘standard’ to signify use of a field standard can be confusing as there are a number 

of different meanings associated with ‘standard’. It could be a documentary standard, i.e., HB 44; a primary 

standard used to realize the SI, i.e., Watt Balance; a laboratory reference standard used to ensure traceability 

of laboratory measurements to the SI, i.e., NIST calibrated laboratory standards; a laboratory check standard 

used to monitor the laboratory process. Use of the single word ‘standard’ requires that the reader understand 

completely the context of its use. Instead using the term Field Standard ensures that the reader understands 

that the item described is a robust working standard used in field conditions to ensure traceability of the 

subordinate measurements to the SI and leaves no ambiguity in its meaning.

Thus, the recommended changes to HB 44 align that document with the HB 130, removing ambiguity and 

adding clarity to the use of Field Standards for device testing. 

Handbook 130 does NOT contain the term transfer standard in any location and already contains the 

definition and appropriate use of the term Field Standard in the following locations:

1.12. Standard, Field. – A physical standard that meets specifications and tolerances in NIST Handbook 

105-series standards (or other suitable and designated standards) and is traceable to the reference or working 
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standards through comparisons, using acceptable laboratory procedures, and used in conjunction with 

commercial weighing and measuring equipment. 

(Added 2005)

Uniform Weights and Measures Law

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 NIST, shall be the state reference and working standards 

of weights and measures, and shall be maintained in such calibration as prescribed by the NIST as 

demonstrated through laboratory accreditation or recognition. All field 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 2005)

Section 12. Powers and Duties of the Director 

The Director shall:

...

(h) verify the field standards for weights and measures used by any jurisdiction 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, and approve the same when found to be correct; 

(Amended 2005)

Uniform Regulation for the Voluntary Registration of Servicepersons and Service Agencies for 

Commercial Weighing and Measuring Devices

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 

calibrated weights and measures field 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 standards and equipment (see Section 5, Minimum Equipment).

Section 9. Examination and Calibration or Certification of Standards and Testing Equipment All field 

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 verification and calibration 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 standards or testing equipment that have 
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not been calibrated or verified by the Director. In lieu of submission of physical standards, 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 which the state will accept calibration 

reports. The state shall retain the right 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. 

(Added 1966) (Amended 1984, 1999, and 2005) 

The Committee received written comments on all items in Block 4 and Block 5, as well as LPG-4 and 

MFM-2 emphasizing the need for there to be more study and discussion of the issues to assess the 

ramifications of all the proposed changes. The Committee also received written comments from the SMA 

that it looks forward to further information on these items and stating that it is important to be consistent in 

our use of terms across multiple sections of NIST Handbook 44. The Committee agreed to carryover this 

group of items on its 2019 agenda to allow for further discussion and development of these proposals.

The Committee received written comments on all items in Block 4 and Block 5, as well as LPG-4 and 

MFM-2 emphasizing the need for there to be more study and discussion of the issues to assess the 

ramifications of all the proposed changes. The Committee also received written comments from the SMA 

that it looks forward to further information on these items and stating that it is important to be consistent in 

our use of terms across multiple sections of NIST Handbook 44. The Committee agreed to carryover this

group of items on its 2019 agenda to allow for further discussion and development of these proposals.

At the 2019 Interim Meeting the S&T Committee decided to combine the items on the agenda dealing with 

the issue of transfer standard (including items already combined into blocks) into one block. Block 1 (New) 

of the Interim Meeting report now includes GEN-3, Block 1 (original items from the 2019 interim agenda 

that appeared under Block 1), Block 2, LPG-3, and MFM-5, which were all separate items and blocks of 

items on the S&T Committee’s 2019 Interim Meeting agenda (NCWM Publication 15). Agenda items 

GEN-3, Block 1, Block 2, LPG-3, and MFM-5 are listed separately on the Interim agenda with a note added 

beneath each individual item referring the reader to the New B1 items. All items under this New B1 have 

retained the same numbering system for ease in referring to the appendix for discussion on each item.

At the 2019 Annual Meeting, Mr. Brett Gurney (NCWM Chairman) commented regarding the formation 

of a Task Group assigned to further develop this block proposal. The TG is charged with providing 

definitions for various types of standards (transfer, field, reference, etc.) as well as the criteria to be met by 

these types of standards. The completion date given to the TG is July 2021. The Committee agreed to the 

Assigned status for this block of items and looks forward to hearing updates from the TG. The Chair of the 

task group was:

Mr. Jason Glass

Kentucky Department of Agriculture

(502) 573-0282, jason.glass@ky.gov

At the 2020 Interim Meeting, the Field Standard TG Chair Glass reported that the Task Group met prior to 

the Interim meeting and has begun discussion of the items under Block 1. Mr. Glass stated that bi-weekly 

teleconference meetings were scheduled and that the group was optimistic but had significant work to 

accomplish.

Mr. Russ Vires (speaking on behalf of SMA) supports the Scale item, SCL 18.1; in this block, Mr. Dimitri 

Karimov (Meter Manufacturers Association) supports the Task Group activities, Mrs. Tina Butcher (NIST 

OWM) was encouraged with the progress on terminology and provided an update on the Mass Flow Meter 
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testing reporting that field testing was conducted October 28 to November 1, 2019 and that State and 

Industry participation included Colorado, Florida, Oregon, Emerson, and Tulsa Gas Technology.

Mr. Kurt Floren (Los Angeles County, California) raised concerns with GEN-19.1. regarding the definition 

of “Standard, Field” and its reference to “stable” standards and how long a standard is expected to be stable, 

which is typically 1-year, for which he believes should be longer. Mr. Floren also questioned the statement 

in the definition “tested over a range of environmental and operational conditions that the measuring devices 

is used...” Mr. Floren noted that he was unsure if all laboratories will have the capabilities to test over this 

wide range of conditions. Mr. Floren also expressed concerns with the definition “Standard, Transfer” 

citing that this standard may not meet the fundamental considerations requirement for standards over a long 

period of time or wide range of environmental conditions. 

Mr. Steve Harrington (Oregon) echoed Mr. Floren’s comments. Field Standard TG Chair Glass responded 

that these are concerns of the TG and these issues will be discussed and considered as the TG develops 

these items. 

During the Committee’s work session, the Committee agreed that this item should remain an Assigned 

item.

At the 2021 Interim Meeting the NCWM Field Standard TG Chair, Mr. Glass provided an update on the 

Task Group activities. Mr. Glass reported that the Field Standard Task Group is following the activities of 

the NIST Master Meter Project and that the Task Group reviewed API specifications for use of master 

meters as a standard and a test protocol that will be used to ensure uniformity in collecting data on master 

meters used as field standards. He also reported that the TG does not have a recommendation for this item. 

Mr. Glass also reported that he would be stepping down as the TG Chair. Mr. Mike Keilty (Endress+Hauser 

AG) thanked Chair Glass and the TG for their work and requested that Block 1, LPG-15.1, N.3. and Block 

1 MFM-15.1, N.3 be removed from Block 1 items and to allow those items to move forward separate from 

the other Block 1 Items. Mr. Keilty stated that similar language was added to the Hydrogen code and that 

the proposed language in LPG-15.1 N.3. and MFM-15.1, N.3 will allow for the recognition of master meters 

as field standards. Mr. Henry Oppermann (WM-Consulting), stated that data is needed to ensure that master 

meters can be used over a range of conditions. Mr. Robert Murnane (Seraphin) stated that jurisdictions 

have the ability to use meters and that Block 1 LPG-15.1, N.3 and Block 1 MM-15.1, N.3 should remain in 

Block 1 until data is available to support the use of master meters as a standard. Mr. Keilty mentioned that 

there has been useful dialog regarding master meters in the TG, but that he is concerned that the TG is not 

close to deciding and he expressed concerns with the TG’s focus on the NIST Master Meter Project. Mrs. 

Tina Butcher (NIST OWM) provided an update on the NIST Master Meter Project and noted that States 

have the regulatory powers to accept or reject a standard. She also mentioned that NIST is working with 

States to collect data needed to assess master meters and preliminary testing was conducted and data was 

collected on CNG at Tulsa Gas Technology’s facility in fall 2019. Ms. Diane Lee (NIST OWM) noted that 

NIST OWM feels that it is premature to add more language to the Handbook 44 on master meters without 

data to support its use. 

During the Committee’s work session, the Committee agreed to keeps all items in Block 1 and that this 

item should remain with an Assigned status.

At the 2021 Annual Meeting, Mr. Glass reported that he would be stepping down as the Field Standard TG 

Chair. The Committee heard updates from members of the Task Group during open hearings. Mr. Keilty

noted that two of the items had been on the agenda since 2015 and requested that they be removed from the 

block and recommended recognizing the use of master meters. Other comments were to keep the items 

together until data is analyzed from the NIST Field Reference Standard Work Group to support the use of 
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master meters but that if some items were removed from the block, all items should be removed from the 

block. Based on comments heard during the 2021 Annual Meeting, the S&T Committee recommended that 

all items that were included in Block 1 “Terminology For Testing Standards” that originally appeared as a 

separate item or a separate block of items on the S&T agenda in and prior to 2019, be removed from Block 

1 “Terminology For Testing Standards” and appear as originally presented. 

During the 2021 Committee work session the Committee recognized that the Task Group has accomplished 

all it is able to at this point and is recommending the Task Group be disbanded and will make said 

recommendation to the NCWM Chairman. The Committee agreed to break all items in Block 1 into 

individual items and designate them all as Developing. The Committee thanks the Task Group and its 

members for their work.

At the 2022 Interim Meeting, Ms. Diane Lee (NIST OWM, submitter) provided written comments 

recommending withdrawal of the block. Ms. Lee spoke during open hearings to explain that while the 

items have merit and will continue to be worked on, they should be withdrawn at this time while the 

language and terms are aligned with other items in the handbook.

Written comments were received from Mr. Russ Vires, representing the Scale Manufacturers Association 

(SMA). Mr. Vires (representing the SMA) also spoke during the open hearing to express the support for 

further development. Additional comments were heard from regulatory officials recommending 

development of the block items.

During the S&T Committee work session, the Committee agreed to recommend this item for withdrawal to 

allow for the submitter to continue work on this item and allow for alignment as other related items in the 

Handbook are developed and move forward.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Russell Vires (Mettler Toledo): there are some conflicts now that GEN-19.1 has been removed (from 

the block). OTH-18.1: some conflicts there. This needs additional work. Recommend that it remains 

developing to give stakeholders opportunity to properly vet item

Ms. Diane Lee (NIST OWM): Russ is correct. Previous agenda - OTH-18.1 was listed as a separate item 

on the agenda but it has always been a part of block 1 (concern raised). That is fixed and 18.1 is included. 

What do we call master meters? What do we call transfer standards? NIST wants to call everything a field 

standard. All items were in a block - 18.1 should remain in the block but it was removed. NIST supports 

developing.

Mr. Kurt Floren (Los Angeles County, California): won’t comment on tech. aspects. Question on status? 

SCL-18.1 and OTH-18.3: these are shown as Assigned items. Have they been assigned to a task force? 

Are they still in the hands of NIST? Need to define the terms (field standard and transfer standard). 

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): to Mr. Floren - it had previously been Assigned 

but the Task Group disbanded to allow NIST to continue their work on the questions at hand. They are 
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looking to have members of that group to join the NIST group to gain more understanding. This is a typo 

- should be changed to developmental.

Mr. Matt Douglas (California - DMS): California supports further development. 

Mr. Don Onwiler (NCWM): the report from S&T said that the block would be broken up. National 

Committee agreed to separate blocks. They just forgot to delete the extra item. National Committee will 

sort it out. Scratch 18.1 as individual item.

Ms. Cadence Matijevich (Nevada): NIST HB 105 - may be a useful reference doc. To look at the 

definitions. To avoid conflict bet. NIST HB 44 and NIST HB 105.

The WWMA S&T Committee recommends the status remain developmental.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Oppermann (Weights and Measures Consulting, 

Seraphin) stated that you can’t call everything a Field Standard, and that he supports this item remaining 

Developing so the group can work with OWM to align their terminology. 

Mr. Russ Vires (speaking on behalf of SMA) stated they support SCL/ABW/AWS because it is important 

to use consistent terminology across Handbook 44.

Mr. Russ Vires (speaking on behalf of Mettler Toledo) stated that this item conflicts with Gen 19.1, and 

that he supported this item remaining Developing. 

This Committee feels that more work needs to be done on this item regarding consistent terminology. 

This Committee recommends this item remain Developing pending the Field Standard Task Group finding 

a new Chairperson. 

 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Henry Opperman (W&M Consulting/Seraphin) commented that this item should remain a Developing 

item along with continued discussions with NIST OWM.

 

Mr. Lou Straub (SMA) supports the proposal as it applies to the items SCL-18.1, ABW-18.1, and AWS18.1 items, and looks forward to further development by the Task Group. 

Mr. Henry Opperman (Seraphin) commented that this block originally contained (Gen 19.1) that was 

separated from the block and recommends further development.

The NEWMA Specifications and Tolerances Committee recommends that this item remain in Developing 

Status. 

During the 2022 Annual Meeting Open Hearing this item was not discussed because the item was 

withdrawn at the 2022 Interim Meeting. 
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Central Weights and Measures Association 

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Ms. Diane 

Lee (NIST OWM) mentioned that other items have been taken out of this block. Will be working with 

Seraphin to come up with better language. Is maybe “Meter” more suitable. Should stay as Developing. 

Mrs. Tina Butcher (NIST OWM) submitted OTH 22.1 and will help develop more. Mr. Lou Straub (SMA)

can support ABW-18.1 and AWS-18.1. Mr. Charles Stutesman (Kansas) has issues with term “master 

meter”. Mr. Ivan Hankins (Iowa): why can’t we use the term “prover” doesn’t understand “transfer meter 

or master meter”.

CWMA S&T Committee recommends item as Developing.

During the 2022 Annual Meeting Open Hearing this item was not discussed because it was withdrawn at 

the 2022 Interim Meeting.

ITEM BLOCK 2 (B2) A DEFINE TRUE VALUE FOR USE IN ERROR CALCULATIONS

B2: A SCL-20.3 A S.5.4. Relationship of Minimum Load Cell Verification Interval to the Scale 

Division

B2: A SCL-20.4 A Table 3. Parameters of Accuracy Classes.

B2: A SCL-20.5 A Table S.6.3.a. Marking Requirements, Note 3.

B2: A SCL-20.6 A T.N.1.2. Accuracy Classes and T.N.1.3. Scale Division.

B2: A SCL-20.7 A Table 7. Maintenance Tolerances

B2: A SCL-20.8 A Table 8. Recommended Minimum Load

NOTES: 

1. At the 2020 NCWM Interim Meeting the committee agreed that GEN-20.1, SCL-20.1 and SCL20.2 should be removed from Block 2 and given individual consideration. The items included in 

this block 2 are SCL-20.3, SCL-20.4, SCL-20.5, SCL-20.6, SCL-20.7 and SCL-20.8.

2. While this item was carried over from the 2020 Interim Meeting, it was not a voting item and 

therefore not discussed during the continuation of the 2020 Annual Meeting. Instead, it was placed 

on the 2021 Interim Meeting’s agenda and was discussed during that meeting.

Source: Mr. Ross Andersen (Retired)

Purpose and Justification:

This proposal has four parts:

1. Clarify the concepts in determining error in verification,

2. Correct Code references to ensure correct reference to either e or d, as appropriate,

3. Correct Code references regarding issues of scale suitability Table 8, and

4. Explain why e and d are not connected
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OWM Executive Summary for Item Block 2 (B2) – Define True Value for Use in Error

Calculations

OWM Recommendation: OWM awaits the further revision of various items in this block by the TG 

assigned.

• The items in this block represent very significant changes to the Scales Code of NIST HB 44 in that 

they are an attempt to clarify which value: the value of the scale division (d) or verification scale 

division (e), are the paragraph requirements to be based. It is important that everyone agree, however, 

but this has not yet been the case.

• OWM disagrees with several of the changes proposed by the different items in this block as shown 

in the Committee’s current agenda. 

• The proposals in the Committee’s current agenda were never updated, however, to reflect changes 

that members of the NCWM’s Verification Scale Division (e) Task Group (TG) had agreed upon and 

included in TG’s second report to the Committee. 

• There seemed to be a misunderstanding between the TG and Committee on who would update the 

different items in this block to reflect the TG’s second report and this effort was never completed.

• It was decided during the 2022 NCWM Interim Meeting that the Block 2 items would be reassigned 

to the TG for updating to reflect changes decided upon by the TG as indicated in its second report.

• OWM has been asked to continue its participation on the TG following the unexpected passing of 

Mr. John Barton, who had been serving as OWM’s Technical Advisor to the group. Mr. Rick 

Harshman and Mr. Jan Konijnenburg plan to provide assistance in this regard. 

• OWM looks forward to reviewing the updated versions of the different proposals in this block once 

they are made available by the TG. 

Table 3. Summary of Recommendations

B2 – Define True Value for Use in Error

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM

Letters of Support Letters of Opposition Notes

Industry
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Table 3. Summary of Recommendations

B2 – Define True Value for Use in Error

V D W A I Notes* Comments

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

B2: SCL-20.3 A S.5.4. Relationship of Minimum Load Cell Verification Interval to the Scale 

Division

Amend Handbook 44, Scales Code as follows: 

S.5.4. Relationship of Minimum Load Cell Verification Interval Value to the Scale Division – The 

relationship of the value for the minimum load cell verification scale interval, vmin, to the verification 

scale division, d e, for a specific scale using National Type Evaluation Program (NTEP) certified load 

cells shall comply with the following formulae where N is the number of load cells in a single 

independent1 weighing/load-receiving element (such as hopper, railroad track, or vehicle scale 

weighing/load-receiving elements): 

(a) vmin

N

≤ d e

for scales without lever systems; and

(b) vmin 

N scale multiple ( )

≤

×

d e

for scales with lever systems.

 1”Independent” means with a weighing/load-receiving element not attached to adjacent elements and 

with its own A/D conversion circuitry and displayed weight.

[*When the value of the scale division, d, is different from the verification scale division, e, for the 

scale, the value of e must be used in the formulae above.]

This requirement does not apply to complete weighing/load-receiving elements or scales, which satisfy 

all the following criteria:

- the complete weighing/load-receiving element or scale has been evaluated for compliance with 

T.N.8.1. Temperature under the NTEP;

- the complete weighing/load-receiving element or scale has received an NTEP Certificate of 

Conformance; and
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- the complete weighing/load-receiving element or scale is equipped with an automatic 

zero-tracking mechanism which cannot be made inoperative in the normal weighing mode. (A 

test mode which permits the disabling of the automatic zero-tracking mechanism is permissible, 

provided the scale cannot function normally while in this mode.

[Nonretroactive as of January 1, 1994]

(Added 1993) (Amended 1996, and 2016, and 20XX) 

B2: SCL-20.4 A Table 3. Parameters of Accuracy Classes.

Amend Handbook 44, Scales Code as follows:

Table 3.

Parameters for Accuracy Classes

Class

Value of the Verification Scale 

Division e1 

(d or e1)

Number of Scale4 Divisions (n)

Minimum Maximum

SI Units

I equal to or greater than 1 mg 50 000 --

II 1 to 50 mg, inclusive 100 100 000

equal to or greater than 100 mg 5 000 100 000

III2,5 0.1 to 2 g, inclusive 100 10 000

equal to or greater than 5 g 500 10 000

III L3 equal to or greater than 2 kg 2 000 10 000

IIII equal to or greater than 5 g 100 1 200

U.S. Customary Units

III5 0.0002 lb to 0.005 lb, inclusive 100 10 000

0.005 oz to 0.125 oz, inclusive 100 10 000

equal to or greater than 0.01 lb 500 10 000

equal to or greater than 0.25 oz 500 10 000

III L3 equal to or greater than 5 lb 2 000 10 000

IIII greater than 0.01 lb 100 1 200

greater than 0.25 oz 100 1 200

1 For Class I and II devices equipped with auxiliary reading means (i.e., a rider, a vernier, or a least 

significant decimal differentiated by size, shape, or color), the value of the verification scale division 

“e” is the value of the scale division immediately preceding the auxiliary means. The manufacturer 

may design a scale such that the verification scale division e does not be equal to the scale division d. 

To ensure the correct value for e is used, refer to marking requirements in footnotes 3 and 4 to Table 

S.6.3.a. and Table S.6.3.b.

(Amended 20XX)
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B2: SCL-20.5 A Table S.6.3.a. Marking Requirements, Note 3.

Amend Handbook 44, Scales Code as follows: 

3. The device shall be marked with the nominal capacity. The nominal capacity shall be shown together 

with the value of the scale division “d” (e.g., 15 × 0.005 kg, 30 × 0.01 lb, or capacity = 15 kg, 

d = 0.005 kg) in a clear and conspicuous manner and be readily apparent when viewing the reading 

face of the scale indicator unless already apparent by the design of the device. Each scale division 

value or weight unit with its associated nominal capacity shall be marked on multiple range or 

multi-interval scales. In the absence of a separate marking of the verification scale division “e” (see 

Note 4), the value of the verification scale division e shall be equal to the value of the scale division 

d.

[Nonretroactive as of January 1, 1983] 

(Amended 2005 and 20XX)

B2: SCL-20.6 A T.N.1.2. Accuracy Classes and T.N.1.3. Scale Division.

Amend Handbook 44, Scales Code as follows: 

T.N.1.2. Accuracy Classes. – Weighing devices are divided into accuracy classes according to the number 

of scale divisions (n) and the value of the verification scale division (d) (e). 

2 A Class III scale marked “For prescription weighing only” may have a verification scale division (e) 

not less than 0.01 g. 

(Added 1986) (Amended 2003)

3 The value of a the verification scale division (e) for crane and hopper (other than grain hopper) scales 

shall be not be less than 0.2 kg (0.5 lb). The minimum number of scale divisions shall not be less than 

1000.

(Amended 20XX)

4 On a multiple range or multi-interval scale, the number of divisions for each range independently shall 

not exceed the maximum specified for the accuracy class. The number of scale divisions, n, for each 

weighing range is determined by dividing the scale capacity for each range by the verification scale 

division, e, for each range. On a scale system with multiple load-receiving elements and multiple 

indications, each element considered shall not independently exceed the maximum specified for the 

accuracy class. If the system has a summing indicator, the nmax for the summed indication shall not 

exceed the maximum specified for the accuracy class.

(Added 1997)

5 The minimum number of scale divisions for a Class III Hopper Scale used for weighing grain shall be 

2000.)

[Nonretroactive as of January 1, 1986]

(Amended 1986, 1987, 1997, 1998, 1999, 2003, and 2004, and 20XX)
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T.N.1.3. Scale Division. – This Code contains references to two types of scale divisions, the 

verification scale division (e) and the scale division (d) (see definitions in Appendix D.). The tolerance 

for a weighing device is in the order of magnitude of related to the value of the scale division (d) or 

the value of the verification scale division (e) and is generally expressed in terms of d or e. Other technical 

requirements may reference either the verification scale division (e) or scale division (d) as 

appropriate. The values of (e) and (d) are chosen by the manufacturer and are marked on the device 

pursuant to S.6.3., except that d is not used in reference to an analog device, such as an equal-arm 

balance, where the graduations do not correspond to units of weight.

B2: SCL-20.7 A Table 6. Maintenance Tolerances

Amend Handbook 44, Scales Code as follows: 

Table 6.

Maintenance Tolerances

(All values in this table are in verification scale divisions)

Tolerance in Verification Scale Divisions

1 2 3 5

Class Test Load

I 0 - 50 000 50 001 - 200 000 200 001 +

II 0 - 5 000 5 001 - 20 000 20 001 +

III 0 - 500 501 - 2 000 2 001 - 4 000 4 001 +

IIII 0 - 50 51 - 200 201 - 400 401 +

III L 0 - 500 501 - 1 000 (Add 1 d e for each additional 500 d e or fraction thereof)

B2: SCL-20.8 A Table 8. Recommended Minimum Load

Amend Handbook 44, Scales Code as follows: 

Table 8.

Recommended Minimum Load

Class Value of Scale Division

(d or e*)* 

Recommended Minimum 

Load

(d or e*)*

I equal to or greater than 

0.001 g

100

II 0.001 g to 0.05 g, inclusive 20

equal to or greater than 0.1 g 50

III All** 20

III L All 50
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Table 8.

Recommended Minimum Load

IIII All 10

*For Class I and II devices equipped with auxiliary reading means (i.e., a rider, a 

vernier, or a least significant decimal differentiated by size, shape or color), the value of 

the verification scale division “e” is the value of the scale division immediately preceding 

the auxiliary means. For Class III and IIII devices the value of “e” is specified by the 

manufacturer as marked on the device; “e” must be less than or equal to “d.” Scales 

manufacturers are permitted to design scales where the value a verification scale division 

e differs from the displayed scale division d. If the marked value of e is less than the value 

of d, use e in interpreting the Table. In all other cases use the value of d. Refer to marking 

requirements for d and e in footnotes 3 and 4 to Table S.6.3.a. and Table S.6.3.b.

(Amended 20XX)

**A minimum load of 10 d e is recommended for a weight classifier marked in accordance 

with a statement identifying its use for special applications.

(Amended 1990) (Amended 20XX)

NIST OWM Detailed Technical Analysis: 

OWM looks forward to reviewing updates to the various items in this block once the NCWM Verification 

Scale Division (e) Task Group (TG) has completed its work amending the current proposals to reflect the 

agreed upon changes reported by the TG in its second report. Since there have been no updates to the 

different items in Block 2 since they were first submitted, OWM’s analysis of this group of items remains 

unchanged from the 2022 NCWM Interim Meeting as follows:

 

It remains clear that not everyone agrees with the changes proposed by this block of items given that none 

of the four regional weights and measures associations, nor the SMA, all of which met in the fall of 2021, 

could recommend to the national S&T committee advancement of this block of items to a voting status. 

Two of the regional associations recommended the block be reassigned to the Verification Scale Division 

Task Group. The other two regional associations recommended the block be developing. The SMA 

supported further development and the work of the Verification Scale Division (e) Task Group. We too 

disagree with some of the changes proposed. Consequently, as a group of items considered together, OWM 

cannot support them. 

Although we are aware of the existence of a second draft report from the Verification Scale Division (e) 

Task Group that we think proposes, or at least suggests, additional changes/updates to the items in this 

block, we do not believe any of the items in Block 6 have changed since that report was first made available 

to us. We are hopeful, however, that some of the proposals in this block have been updated (but not yet 

published) or will be updated in the very near future and those updates will resolve, at least some concerns. 

We base this hope on comments made by Mr. Henry Oppermann (Weights and Measures Consulting, LLC) 

during Committee open hearings at the 2021 NEWMA Interim Meeting. Mr. Oppermann reported during 

open hearings that he had talked to the submitter of this block of items and the two had reached agreement 

on some needed changes to the proposals. Mr. Oppermann commented also, that he thought those agreed 

upon changes had perhaps already been made. Consequently, the draft of Block 2 items in NEWMA’s 

2021 S&T Interim Meeting agenda was not, in Mr. Oppermann’s opinion, the most recent draft. We are 
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somewhat encouraged by this news because we share at least some of Mr. Oppermann’s concerns with 

respect to the current items in this block. 

Further evidence that the proposals in the Committee’s 2022 Interim Meeting agenda (i.e., NCWM 

Publication 15) may have been updated, but not yet published or widely distributed, are comments made 

by the Chairman of the Verification Scale Division (e) Task Group during Committee open hearings at the 

2021 CWMA Annual meeting. That is, the CWMA’s S&T 2021 Annual Report indicates that Mr. Doug 

Musick, who was Chairman of the Verification Scale Division (e) Task Group during its existence, provided 

updates from the Task Group and would be providing changes to the item to NCWM S&T Committee 

before the July NCWM Annual meeting. Based on our review and comparison of the Block 2 items in the 

CWMA’s 2021 S&T Annual Meeting Agenda and the Committee’s 2022 Interim Meeting agenda (i.e., 

NCWM Publication 15) none of the proposals have changed. 

If there does, in fact, exist a more current draft of the proposals in Block 2 and that draft gets introduced on 

or before the 2022 NCWM Interim Meeting, we encourage the Committee to provide adequate time for 

review and discussion opposed to simply advancing any new draft for vote during the 2022 NCWM Interim 

Meeting. There are many changes proposed by this block of items (i.e., there are six individual items in 

all) and their significance should be of great enough concern to warrant, in our opinion, sufficient time for 

review and discussion, especially in light of the fact there still exists disagreement on the current proposals. 

As noted in earlier OWM comments and recommendations, the different proposals included in this block 

present several very significant changes to the Scales code of HB 44 with respect to the application of HB 

44 requirements to scales having different values of e and d. Given these two values most often differ by 

a factor of ten, it is of utmost importance that everyone agree on which value is the application of the 

different HB 44 requirements to be based. 

Summary of Discussions and Actions:

During the 2022 NCWM Interim Meeting, Mr. Rick Harshman (NIST OWM) commented that the items in 

this block represent very significant changes to the Scales Code of NIST HB 44 in that they are an attempt 

to clarify which value, the value of the scale division (d), or verification scale division (e), are the paragraph 

requirements to be based. It is important that everyone agree; however, but this has not yet been the case. 

Mr. Harshman noted that OWM disagreed with several of the changes proposed by the different items in 

this block as shown in the Committee’s current agenda. Mr. Harshman also reported that the various Block 

2 items in the Committee’s current agenda fail to reflect changes agreed to by members of the NCWM’s 

Verification Scale Division (e) Task Group (TG) as indicated in its second report to the Committee. That 

is, the proposals hadn’t been updated following the TG’s submission of its second report to the Committee. 

There seemed to be a misunderstanding between the TG and Committee on who would perform this work 

and it never got done. OWM looked forward to reviewing the proposals once this updating had been 

completed. 

Mr. Doug Musick (Kansas) Chairman of the Verification Scale Division (e) TG acknowledged the accuracy 

of Mr. Harshman’s reporting of the misunderstanding between the TG and Committee. He then requested 

the Committee either reassign the Block 2 items to the TG, or, if the Committee preferred, the Committee 

could perform the updating itself based on the TG’s most recent report. Mr. Musick also noted that the 

TG’s second report was included in Appendix A of the Committee’s 2022 Interim Agenda (NCWM 

Publication 15). 

Mr. Russ Vires (Mettler Toledo, LLC) speaking on behalf of the SMA stated that the SMA supports the 

further development of this item and the work of the Verification Scale Division (e) Task Group. The SMA 
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would also like to encourage the use of the terminology “Verification Interval” for “e” and “Scale Division” 

for “d” in every instance that it appears in this item.

The Committee also received several comments in support of reassigning the block of items to the TG for 

further revision. 

The Committee, in consideration of the comments received, agreed to reassign the block of items to the 

Verification Scale Division (e) TG for additional updating.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Matt Douglas (California - DMS): the language is not clear, recommend that this item be withdrawn. 

(the whole block)

Mr. Russell Vires (Scale Manufactures Association): this is a carryover item. SMA supports further 

development of this item, recommend that the SMA encourage the use of term: Verification Scale Interval 

for (e) and Scale Division for (d). (He can send info.) States that his comments are the same from the 

Annual meeting.

Ms. Diane Lee (NIST OWM): NIST OWM comments on this item are posted on NCWM website.

The WWMA S&T Committee recommends that this item remain Informational with concern given to the 

comments given during the WWMA open hearings. During the Committee work session, clarification was 

given regarding Committee member Mr. Matt Douglas’ (California - DMS) testimony questioned whether 

or not the item provides assistance to an Inspector in the field in the performance of their job. 

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Russ Vires (SMA) supported further development of 

this item and recommended the descriptive name changes for “e” and “d” as posted on the NCWM website. 

This Committee recommends this item move forward with an Assigned status. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Rick Harshman (NIST OWM) recommends keeping this item in informational status due to the fact 

that the National S&T Committee has taken ownership and interpretations have been provided at NTEP 

and weighing sector meetings. Meeting notes are available on NCWM website.

Mr. Henry Opperman (Weights and Measures Consulting) objected to many of the blocked items and 

recommend to keep this item in Informational status.
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Mr. Lou Staub (SMA) suggested the use of the term “verification scale interval” for “e” and “scale division” 

for “d”.

Mr. John McGuire (New Jersey)- Recommends keeping the item in Informational status.

The NEWMA Specifications and Tolerances Committee recommends that this item be kept in 

Informational status. 

During the 2022 Annual Meeting Open Hearings, Mr. Russ Vires (Mettler Toledo, LLC) speaking on behalf 

of the SMA recommended the identical changes to the individual items in Block 2 as shown in the SMA 

reporting contained within this report for the SMA’s Spring 2022 meeting. Mrs. Tina Butcher (NIST 

OWM) indicated she believes the latest revisions from task group have addressed concerns.

After hearing comments from the floor, the Committee recognized the need to further develop this block 

and recommended the block retain Assigned status.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mr. Lou 

Straub (SMA) supports item. Would like to see it written that “scale division” will have value of “d” and 

“verification scale interval” for “e”. 

CWMA S&T Committee recommends that item be assigned back to the Verification Scale Division Task 

Group.

During the 2022 CWMA Annual Meeting Open Hearings the Committee received the following comments: 

Mr. Russ Vires (SMA) - The SMA supports the further development of this item and the work of the 

Verification Scale Division (e) Task Group. Recommendation: The SMA would also like to encourage 

the use of the terminology “Verification Interval” for “e” and “Scale Division” for “d” in every instance 

that it appears in this item. 

Mr. Loren Minich (Kansas) - Items shown under consideration are not the items the task group has 

submitted. The SMA recommendations conflict with current task group verbiage.

Mr. Doug Musick (Kansas) – This proposal got put into the National Committee Agenda Appendix for 

some reason. Hope to rebuild the task group and get cleaned up before 2022 national. “verification interval” 

should be “verification scale division” (e), and “displayed scale division” (d). Having (d) and (e) in the 

same original table was confusing to inspectors. The current task group changes won’t be in Pub 16 for the 

2022 National meeting.

Mr. Loren Minich (Kansas) - Prefers the S&T Committee to evaluate the Appendix since it’s more up to 

date.

The CWMA S&T Committee recommends this item remain as Assigned.

SMA 
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During the 2021 Fall Meeting the SMA supports the further development of this item and the work of the 

Verification Scale Division (e) Task Group. The SMA would also like to encourage the use of the 

terminology “Verification Interval” for “e” and “Scale Division” for “d” in every instance that it appears in 

this item. The following changes are recommended to the individual items in this block:

B2: SCL-20.3 S.5.4 Relationship of Minimum Load Cell Verification Interval: No change

B2: SCL-20.4 Table 3. Parameters of Accuracy Classes

Recommendation: The SMA recommends the following change to Table 3, Footnote 1: The 

manufacturer may design a scale such that the verification scale division verification interval e 

does not be equal to the scale division d.

B2: SCL-20.5 Table S.6.3.A. Marking Requirements, Note e: No Change

B2: SCL-20.6 T.N.1.1. Accuracy Classes and T.N.1.3. Scale Division 

Recommendation: The SMA recommends the following change: “... except that (d) is not used 

in reference...”

B2: SCL-20.7 Table 7. Maintenance Tolerances 

Recommendation: The SMA recommends the following change: Table 6. Maintenance 

Tolerances

B2: SCL-20.8 Table 8 Recommended Minimum Load

Recommendation: The SMA recommends the following change: Scales manufacturers are 

permitted may have to design scales where the value a verification scale interval division e differs

not equal to from the displayed scale division d.

During the 2022 Spring Meeting, the SMA reported it supported the further development of this item and 

the work of the Verification Scale Division (e) Task Group. The SMA would also like to encourage the 

use of the terminology “Verification Interval” for “e” and “Scale Division” for “d” in every instance that it 

appears in this item.

The SMA recommended the following changes to the individual items in Block 2:

B2: SCL-20.3 S.5.4 Relationship of Minimum Load Cell Verification Interval: No change

B2: SCL-20.4 Table 3. Parameters of Accuracy Classes

Recommendation: The SMA recommends the following change to Table 3, Footnote 1: Class I 

and II scales may be designed such that the verification scale division verification interval e does 

not be equal to the scale division d.

B2: SCL-20.5 Table S.6.3.A. Marking Requirements, Note 3: No Change

B2: SCL-20.6 T.N.1.2. Accuracy Classes and T.N.1.3. Scale Division

Recommendation: The SMA recommends the following change: “... except that (d) is not used 

in reference...”

B2: SCL-20.7 Table 7. Maintenance Tolerances

Recommendation: The SMA recommends the following change: Table 6. Maintenance 

Tolerances

B2: SCL-20.8 Table 8. Recommended Minimum Load

Recommendation: The SMA recommends striking the following language from the submitter’s 

proposal: Scales manufacturers are permitted to design scales where the value a verification scale 

division e differs from the displayed scale division d.

Rationale: When taken with the SMA’s recommendation for SCL-20.4, this will avoid duplication 

in the HB44 code.

Item Block 2 – Final Report of the Verification Scale Division Task Group
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Participants:

Mr. Doug Musick, Chair (Kansas) 

Mr. Ross Andersen (New York, Retired and original submitter of the item)

Mr. John Barton (NIST OWM)

Mr. Luciano Burtini (Measurement Canada)

Mr. Anthony Bong Lee (Orange County, California) 

Mr. Steve Cook (California, Retired)

Mr. Darrell Flocken (NTEP)

Mr. Eric Golden (Cardinal Scale)

Mr. Jan Konijnenburg (Rice Lake Weighing Systems)

Mr. Richard Suiter (Richard Suiter Consulting)

Mr. Steve Timar (New York) 

Mr. Howard Tucker (Florida) 

The mission of the task group, as defined by the S&T Committee, is to review Handbook 44, Section 2.20. 

Scales and relevant portions of OIML R76, using the items included in S&T Agenda Items: Block 2 as a 

reference point, and recommend changes as necessary to:

1. Clarify how the error is determined in relation to the verification scale division (e) and the scale 

division (d)

2. Clarify which is the proper reference; the verification scale division (e) or the scale division (d) 

throughout this section

3. Ensure proper selection of a scale in reference to the verification scale division (e) and the scale 

division (d)

4. Clarify the relationship between the verification scale division (e) or the scale division (d)

This report is divided into three sections:

1. Clarify the relationship between e and d, i.e., ensure we understand the terms. (Mission items 4 

and1)

2. Propose changes to the Scales Code, if necessary, to ensure the code correctly identifies e or d as 

appropriate to the code paragraph. (Mission items 2 and 3)

3. Address other issues that arose as potential problems that might require additional investigation 

beyond the scope of this workgroup.

PART 1. Clarify the Relationship Between e and d.

We begin by looking at current HB 44 definitions. The verification scale division e is used to express 

tolerance values and it is used in classification. The designations of e and the accuracy class are made by 

the manufacturer. The scale division d is a function of the actual scale function and display. Note that for 

weight classifiers, the weighing instrument may never display quantity at the resolution of e, and for 

ungraduated devices there is no scale division d to permit comparison to e.

verification scale division, value of (e). – A value, expressed in units of weight (mass) and specified by 

the manufacturer of a device, by which the tolerance values and the accuracy class applicable to the device 
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are determined. The verification scale division is applied to all scales, in particular to ungraduated devices 

since they have no graduations. The verification scale division (e) may be different from the displayed 

scale division (d) for certain other devices used for weight classifying or weighing in pre‐determined 

amounts, and certain other Class I and II scales.[2.20]

scale division, value of (d). – The value of the scale division, expressed in units of mass, is the smallest 

subdivision of the scale for analog indication or the difference between two consecutively indicated or 

printed values for digital indication or printing. (Also see “verification scale division.”) [2.20, 2.22]

scale division, number of (n). – Quotient of the capacity divided by the value of the verification scale 

division. [2.20]

e

Capacity n = 

Capacity

The values of e and d must be understood as referring to different things. The verification scale refers to 

the scale of measurement for the reference (or true value), think of the reference standard. The instrument 

scale refers to the scale of measurement of the instrument under test. Consider this assortment of 

instruments in the table below. It should be clear that the divisions of the verification scale do not always 

equal those on the instrument scale and may not even be in the same units. In addition, when we employ 

an artifact, like a test weight or slicker plate measure, the divisions of the verification scale are not visible 

since the artifact represents a single point on the measurement scale of the reference.

Instrument 

Scale

Scale div 

d

Verification “True 

Value” Scale

Scale div e Relation e to d

Rule 1/16 in Standard Rule or Tape 1/16 in e = d

Taximeter 1/10 mi Road Course 2 ft e < d

LMD’s 0.1 gal Prover indication 5 cu in e > d

Mass Flow Meter 1 lb Reference Scale 0.01 lb e < d

Weighing Devices 0.01 lb Test Weight (artifact) mfr choice e < d, e = d, e > d

Test Measure 1 cu in Slicker Plate (artifact) ? e ? d

For weighing instruments, it turns out that e and d have no fixed relationship. It is different for weight 

classifiers (e < d), for most instruments (e = d), and for high resolution instruments (e>d). The critical point 

is that the instrument scale and the verification scale are independent of each other. Once you have 

disconnected e (declared by the manufacturer) from d (displayed on the instrument), it may now become 

evident that much of our confusion arose because we thought of them as connected in some way.

In the graphics below both error and tolerance are always expressed in terms of the divisions (e) of the 

verification scale. The primary assumption is that the verification scale is constant, and it is the displayed 

scales of the instruments we test that move. The scales in black are depicted as in error by +1 e or –1 e.

Error of delivery =

verification scale – instrument scale

 + in excess

 – in deficiency
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Error of Indication = 

instrument scale – verification scale

 + overregistration

 – underregistration

Much of our confusion arises because scales are tested using artifacts with no visible scale divisions. We 

could mirror this in the test of a fuel dispenser. Normally you stop the test at 5 gallons on the instrument 

scale and read the error as – 3 cu in from the test measure (verification) scale. Now change that procedure 

and stop the test at the zero mark on the test measure. How would you determine the error? Assume the 

instrument now reads 5.012 gal. The error is -0.012 gal (-3 cu in), and we calculate it as verification scale 

– instrument scale. We determined the error from the instrument scale. The verification scale division, 

however, did not switch from the test measure to the instrument simply because we changed the procedure. 

The verification scale division remains 1 cu in and is still on the test measure, the reference.

Consider the Class III scale at right where e = d. 

Technically you can’t see divisions on either scale since 

the artifact has no visible divisions and the instrument 

is digital. The correct instrument indication of 500 d is 

1.2 e short of 500 e on the verification scale. You could 

mirror this by applying 498.8 e of test weights to get 

indication of 500 d. It is not in tolerance, but only if you 

apply error weights in your test.

Consider the Class II scale at right where e = 10 d. You 

can’t see divisions on either scale because the test 

weight is an artifact and the instrument are digital. The 

correct instrument indication of 50,000 d is short of the 

5,000 e on the verification scale by 7 d. Thus, we say 

the error is +0.7 e. Error = instrument scale –

verification scale. This instrument is clearly in 

tolerance. No error weights are necessary to see to finer 

than 1 e.

The principles of classification are found in the 

following HB 44 paragraphs. In principle, the manufacturer tells the official what accuracy is to be applied 

to the instrument.

T.N.1. Principles.

T.N.1.1. Design. – The tolerance for a weighing device is a performance requirement independent of 

the design principle used.

T.N.1.2. Accuracy Classes. – Weighing devices are divided into accuracy classes according to the 

number of scale divisions (n) and the value of the scale division (d).

T.N.1.3. Scale Division. – The tolerance for a weighing device is related to the value of the scale 

division (d) or the value of the verification scale division (e) and is generally expressed in terms of d 

or e.
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Yet, the T.N.1.2. and T.N.1.3. paragraphs conflict with the definitions. According to the definition of e, it 

is e “by which the tolerance values and the accuracy class applicable to the device are determined.” When 

the Scales Code was drafted prior to adoption in 1984, it appears some things were lost in translation from 

the OIML R76 on which it was based. What was lost can be expressed as those things not included in 

HB44 and those things incorrectly translated in HB 44.

For example, R76 expresses the classification information in four required markings, and one auxiliary 

marking. R76 requires marking of Class, Max, e, and Min, and requires marking of d if different from e. 

Those markings describe the maximum and minimum loads and the relative accuracy. In contrast, HB44 

requires marking of Class, capacity, and d, and requires marking of e if different from d. HB 44 does not 

require marking of minimum load. While R76 considers minimum load part of the class structure, HB 44 

does not.

It is this switch of e and d that causes confusion because the translation of R76 to HB 44 lost some of the 

meaning. Much of the second part of this report covers the changes required to rectify the situation. The 

work group is attempting to ensure the Code states e when the requirement applies to e and d when it applies 

to d. The work group is also proposing to add important material from R76 that is missing.

Some additional confusion comes from the stepped 

tolerance structure. For example, it is common to 

think that the instrument gets 1 division of error 

over the first tolerance step (maintenance). The 

correct interpretation of the code requires the 

instrument maintain a % accuracy based on the 

number of divisions of load at the break points. The 

space under the step riser is not supposed to be used 

by the instrument provided you eliminate the 

rounding error.

Between 1 division and 10,000 divisions for Class II in R76, this is 0.02 %. At 10,000 e, 0.02 % is 2 e. At 

1,000 e, 0.02 % is 0.2 e, and at minimum load of 50 e, 0.02 % is 0.01 e. The principle is: the larger the 

number of verification scale divisions (n) the more accurate the instrument must be, i.e. relative error. 

Section 2.2 of R76 makes this clear by stating that e represents absolute accuracy and n represents relative 

accuracy. The Scales Code has no parallel section. It is the relative accuracy that should be our focus, but 

that’s not found in HB 44.

PART 2. Proposed changes to the Scales Code (related issues are grouped for convenience)

Group 1. Changes to clarify definitions relating to e.

verification scale division, value of (e). – A value, expressed in units of weight (mass) and specified by 

the manufacturer of a device, by which the tolerance values and the accuracy class applicable to the device 

are determined. The verification scale division is applied to all scales, in particular to ungraduated devices 

since they have no graduations. The verification scale division (e) may be different from the displayed 

scale division (d) for certain other devices used for weight classifying or weighing in pre-determined 

amounts, and certain other Class I and II scales.[2.20]

(Amended 20XX)
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The last sentence is explained fully in the technical requirements in the Code. The work group finds it 

unnecessary and believe it contributes to confusion.

verification scale division, number of (n). – Quotient of the capacity divided by the value of the 

verification scale division. [2.20]

e

Capacity n = 

(Amended 20XX)

scale division, number of (n). – See “verification scale division, number of (n)”

The addition of the word “verification” to the definition of n is essential since without it the section refers 

to the scale division d. The second definition for n was added as a cross reference since the revision will 

move from the s section to the v section.

Group 2. Changes to ensure proper classification of instruments.

T.N.1.2. Accuracy Classes. – Weighing devices are divided into accuracy classes according to the number 

of verification scale divisions (n) and the value of the verification scale division (d) (e). 

(Amended 20XX)

T.N.1.3. Verification Scale Division. – The tolerance for a weighing device is related to the value of the 

scale division (d) or the value of the in the order of magnitude of the verification scale division (e) and is 

generally expressed in terms of d or e.

(Amended 20XX)

These changes bring the principles in the T.N. section in agreement with the definitions. Classification is 

exclusively based on e.

Table 3. 

Parameters for Accuracy Classes

Class

Value of the Verification Scale 

Division 

(d or e1)

Number of Verification

Scale4 Divisions (n)

Minimum Maximum

SI Units

I equal to or greater than 1 mg 50 000 --

II 1 to 50 mg, inclusive 100 100 

000

equal to or greater than 100 mg 5 000 100 

000

III2,5 0.1 to 2 g, inclusive 100 10 

000

equal to or greater than 5 g 500 10 

000
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Table 3. 

Parameters for Accuracy Classes

III L3 equal to or greater than 2 kg 2 000 10 

000

IIII equal to or greater than 5 g 100 1 

200

The middle section of the table was not included for brevity. Notes continue below:

The changes to the header of Table 3 ensure the classification is based on e consistent with the definitions 

and the principles in T.N.1. The scale division d is not involved in classification. This change should 

reduce confusion. The changes to the notes at the bottom of the table again ensure e is correctly referenced 

instead of d or the “scale division.” Referencing “n” in notes 3, 4, and 5 ensure that it is referring to e since 

n = capacity / e.

1 For Class I and II devices equipped with auxiliary reading means (i.e., a rider, a vernier, or a least 

significant decimal differentiated by size, shape, or color), the value of the verification scale division 

“e” is the value of the scale division immediately preceding the auxiliary means. The verification 

scale division e does not always equal the displayed scale division d. To ensure the correct value for 

e is used, refer to required markings on the device (see also notes 3 and 4 in Table S.6.3.b.).

2 A Class III scale marked “For prescription weighing only” may have a verification scale division (e) 

not less than 0.01 g. 

(Added 1986) (Amended 2003)

3 The value of a verification scale division for crane and hopper (other than grain hopper) scales shall 

be not less than 0.2 kg (0.5 lb). The minimum number of verification scale divisions, n, shall be not less 

than 1000.

4 On a multiple range or multi-interval scale, the number of verification divisions, n, for each range 

independently shall not exceed the maximum specified for the accuracy class. The number of 

verification scale divisions, n, for each weighing range is determined by dividing the scale capacity for 

each range by the verification scale division, e, for each range. On a scale system with multiple 

load-receiving elements and multiple indications, each element considered shall not independently 

exceed the maximum specified for the accuracy class. If the system has a summing indicator, the nmax

for the summed indication shall not exceed the maximum specified for the accuracy class.

(Added 1997)

5 The minimum number of verification scale divisions, n, for a Class III Hopper Scale used for weighing 

grain shall be 2000.)

[Nonretroactive as of January 1, 1986]

(Amended 1986, 1987, 1997, 1998, 1999, 2003, and 2004 and 20XX) 
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Table S.6.3.a.

Marking Requirements

Weighing Equipment 

To Be Marked With ⇓

Weighing, 

LoadReceiving, 

and 

Indicating 

Element in 

Same 

Housing or 

Covered on 

the Same 

CC1

Indicating 

Element not 

Permanentl

y Attached 

to Weighing 

and LoadReceiving 

Element or 

Covered by 

a Separate 

CC

Weighing 

and LoadReceiving 

Element Not 

Permanentl

y Attached 

to 

Indicating 

Element or 

Covered by 

a Separate 

CC

Load 

Cell 

with CC

(11)

Other 

Equipme

nt or 

Device

(10)

Manufacturer’s ID (1) X X X X X

Model Designation and Prefix(1) X X X X X

Serial Number and Prefix (2) X X X X X (16)

Certificate of Conformance 

Number (CC) (23) X X X X X (23)

Accuracy Class (17) X X (8) X (19) X

Nominal Capacity (3)(18)(20) X X X

Value of Scale Division, “d”(3 4) X X

Value of Verification Scale 

Division, “e” (4 3) X X 

Temperature Limits (5) X X X X

Note: The remainder of the table was not included for brevity.

The changes to column 1 in the 7th and 8th rows simply reverse the references to the notes in Table S.6.3.b. 

They reflect the primacy of e in classification, which is addressed in parallel changes to notes 3 and 4 in 

Table S.6.3.b. (see changes to Table S.6.3.b. below).
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Table S.6.3.b.

Notes for Table S.6.3.a. Marking Requirements

1. Manufacturer's identification and model designation and model designation prefix.*

[*Nonretroactive as of January 1, 2003] 

(Also see G-S.1. Identification.) [Prefix lettering may be initial capitals, all capitals or all lower case]

(Amended 2000)

2. Serial number [Nonretroactive as of January 1, 1968] and prefix [Nonretroactive as of 

January 1, 1986]. (Also see G-S.1. Identification.)

3. The device shall be marked with the nominal capacity. The nominal capacity shall be shown together 

with the value of the verification scale division, “e” (e.g., 15 × 0.005 kg, 30 × 0.01 lb, or 

capacity = 15 kg, d e = 0.005 kg) in a clear and conspicuous manner and be readily apparent when 

viewing the reading face of the scale indicator unless already apparent by the design of the device. 

Each verification scale division value or weight unit with its associated nominal capacity shall be 

marked on multiple range or multi-interval scales. In the absence of a separate marking of the scale 

division “d” (see Note 4), the value of the scale division “d” shall be equal to the value of the 

verification scale division “e.”

[Nonretroactive as of January 1, 1983] 

(Amended 2005 and 20XX) 

4. Required only if different from “d” “e.” This does not apply to an ungraduated device (equal arm scale) 

where the graduations do not refer to a fixed weight value. 

[Nonretroactive as of January 1, 1986]

(Amended 20XX)

The original Scales Code adopted 1984 made d the primary mandatory marking but this resulted in 

confusion. The changes make e the mandatory marking and now requires d only if different from e.

The changes regarding multiple range and multi-interval scales makes the note say what we have always 

been applying. The intent was for each range or subrange of the instrument to have marking of capacity 

and e. The “or weight unit” could refer to lb or kg, but that is clearly not the intent. 

There is some concern if this might pose problems for existing equipment. If the marking is of the form 

“capacity 30 lb x 0.01 lb” the workgroup sees not conflict. However, markings in the form “capacity = 

30 lb d = 0.01 lb” would cause a conflict as devices using that form would no longer conform with the 

proposed changes. The work group decided to refer this to the scale manufacturers to see if there are any 

devices in the marketplace that would be affected. We also learned that this might cause a conflict with 

Measurement Canada as they do see devices with markings of capacity= d=. Note this is not an issue when 

e ≠ d as both markings is already required by the combination of notes 3 and 4. If necessary, a note with 

qualification “devices manufactured before January 1, 20XX” could be added to accept existing scales 

marked with d = provided d = e.
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S.1.2.2. Verification Scale Interval Division

The magnitude of the verification scale division e relative to the scale division d for different types 

of devices is given in Table S.1.2.2. Relative Magnitude of e to d.

Table S.1.2.2.

Relative Magnitude of e to d

Type of device (see Note) Relative magnitude of e to d

Graduated, without an auxiliary indicating device e = d 

Graduated, with an auxiliary indicating device e > d and e is chosen by the 

manufacturer according to Table 3. 

and S.1.2.2.1.

Graduated, and marked for use in special applications 

(weight classifier)

e ≤ d and e is chosen by the 

manufacturer according to Table 3. 

and S.1.2.2.4.

Note: Ungraduated devices, e.g. equal arm balances where the scale graduations do not represent 

a fixed weight quantity, are not included in this table since they have no scale divisions (d) to permit 

comparison with (e).

S.1.2.2.1. Class I and II Scales and Dynamic Monorail Scales. – If e ≠ d, the verification 

scale interval division “e” shall be determined by the expression:

d < e < 10 d

If the displayed scale division (d) is less than the verification scale division (e), then the 

verification scale division shall be less than or equal to 10 times the displayed scale division.

The value of e must satisfy the relationship, e = 10k of the unit of measure, where k is a positive 

or negative whole number or zero. This requirement does not apply to a Class I device with 

d < 1 mg where e = 1 mg. If e ≠ d, the value of “d” shall be a decimal submultiple of “e,” and 

the ratio shall not be more than 10:1. If e ≠ d, and both “e” and “d” are continuously displayed 

during normal operation, then “d” shall be differentiated from “e” by size, shape, color, etc. 

throughout the range of weights displayed as “d.”

(Added 1999) (Amended 20XX)

S.1.2.2.2. Class I and II Scales Used in Direct Sales. – When accuracy Class I and II scales 

are used in direct sale applications the value of the displayed division “d” shall be equal to 

the value of the verification scale interval “e.”

[Nonretroactive as of January 1, 2020; to become retroactive as of January 1, 2023]

(Added 2017)

S.1.2.2.3. Deactivation of a “d” Resolution. – It shall not be possible to deactivate the “d” 

resolution on a Class I or II scale equipped with a value of “d” that differs from “e” if such 

action affects the scale’s ability to round digital values to the nearest minimum unit that can be 

indicated or recorded as required by paragraph G-S.5.2.2. Digital Indication and 

Representation.
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(Added 2018)

S.1.2.2.4. Class III and IIII Scales. The value of “e” is specified by the manufacturer as 

marked on the device. Except for dynamic monorail scales, “e” must be less than or equal to 

“d.”

(Added 1999)

S.5.3. S.1.2.2.5. Multi-Interval and Multiple Range Scales, Division Value. – On a 

multi-interval scale and or a multiple range scale, the value of “e” shall be equal to the value 

of “d.”

(Added 1986) (Amended 1995 and 20XX)

S.1.2.2.6. Class IIIL Scales. On Class IIIL scales the value of “e” shall equal the value 

of “d.”

(Added 20XX)

Add new definition: 

auxiliary indicating device. – a means to increase the display resolution of a weighing device, 

such as a rider or vernier on an analog device, or a differentiated least significant digit to the 

right of the decimal point on a digital device. [2.20]

(Added 20XX)

Section S.1.2.2. is a key part of understanding application of e and d. The first change was to make 

references uniform to verification scale “division” as used in all other parts of the code. This section 

currently uses the term verification scale “interval”. Several additions of the term “scale’ were also added 

to S.1.2.2.1. for clarity. Of note, R76 exempts Class I from the e not greater than 10 d requirement when e 

= 1 mg or less.

A major addition is the new text and table in T.1.2.2. This would create a parallel section in HB 44 to R76 

section 3.1.2 and Table 2. This section describes four types of instruments:

1. Graduated without an auxiliary indicating device – most instruments e = d

2. Graduated with an auxiliary indicating device – Class I and II with high resolution e > d

3. Graduated & marked for special applications – weight classifiers (round down instruments) e < d

4. Ungraduated – equal arm balances where graduations don’t refer to fixed weight quantities. No d

These four types also impact application of minimum load in Table 8. 

The current S.5.3. was moved to this section as S.1.2.2.5. to keep these paragraphs dealing with the 

magnitude of e and d together. A new paragraph S.1.2.2.6. was added to address Class IIIL where e should 

always equal d. Now all classes (I, II, III, IIIL, and IIII) are covered in S.1.2.2. to clarify relative magnitude 

of e and d.

The addition of the definition rounds out the expansion of this section 
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S.5.4. S.5.3. Relationship of Minimum Load Cell Verification Interval Value to the Verification Scale 

Division. – The relationship of the value for the minimum load cell verification scale interval, vmin, to the 

verification scale division, d e, for a specific scale using National Type Evaluation Program (NTEP) 

certified load cells shall comply with the following formulae where N is the number of load cells in a single 

independent1 weighing/load-receiving element (such as hopper, railroad track, or vehicle scale 

weighing/load-receiving elements):

(a) vmin ≤ d* e for scales without lever systems; and

 √N

(b) vmin ≤ d* e for scales with lever systems.

 √N x (scale multiple)

[*When the value of the scale division, d, is different from the verification scale division, e, for the 

scale, the value of e must be used in the formulae above.]

This requirement does not apply to complete weighing/load-receiving elements or scales, which satisfy 

all the following criteria:

- the complete weighing/load-receiving element or scale has been evaluated for compliance with 

T.N.8.1. Temperature under the NTEP;

- the complete weighing/load-receiving element or scale has received an NTEP Certificate of 

Conformance; and

- the complete weighing/load-receiving element or scale is equipped with an automatic 

zero-tracking mechanism which cannot be made inoperative in the normal weighing mode. (A 

test mode which permits the disabling of the automatic zero-tracking mechanism is permissible, 

provided the scale cannot function normally while in this mode.

[Nonretroactive as of January 1, 1994]

(Added 1993) (Amended 1996, and 2016, and 20XX) 

The renumbering resulted from the move of S.5.3. to the S.1.2.2. section as S.1.2.2.5. The other changes 

correctly reference e instead of d in this section. Technically, vmin for load cells corresponds to verification 

scale division e for weighing instruments. They are accuracy ratings declared by the manufacturer. There 

is no significant change for the inspector in properly referring to e since for scales where e = d the issue is 

moot and when e ≠ d the section already directed the use of e. With the change the inspector will always 

use e.

Group 3. Changes to clarify appropriate application of tolerances (Marked Scales)

Table 6. 

Maintenance Tolerances

(All values in this table are in verification scale divisions “e”)

Tolerance in Scale Divisions

1 2 3 5

Class Test Load

I 0 - 50 000 50 001 - 200 000 200 001 +

II 0 - 5 000 5 001 - 20 000 20 001 +
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Table 6. 

Maintenance Tolerances

(All values in this table are in verification scale divisions “e”)

Tolerance in Scale Divisions

III 0 - 500 501 - 2 000 2 001 - 4 000 4 001 +

IIII 0 - 50 51 - 200 201 - 400 401 +

III L 0 - 500 501 - 1 000 (Add 1 d e for each additional 

500 d e or fraction thereof)

The proper reference in this section has always been e, and this is how it has always been interpreted. The 

current language says “scale divisions” which technically refers to d. This means we weren’t following the 

Code. The removal of “in Scale Divisions” after Tolerances in the second row was made to provide parallel 

construction with the header for Test Load. The parenthetical at the top should be sufficient to cover both 

sections of the table.

The change for Class IIIL was made since e should be used to specify tolerances and we added S.1.2.2.6. 

requiring that d = e for this class.

T.N.3.4. Crane and Hopper (Other than Grain Hopper) Scales. – The maintenance and acceptance 

tolerances shall be as specified in T.N.3.1. Maintenance Tolerance Values and T.N.3.2. Acceptance 

Tolerance Values for Class IIIL, except that the tolerance for crane and construction materials hopper scales 

shall not be less than 1 e d or 0.1 % of the scale capacity, whichever is less.

(Amended 1986 and 20XX) 

T.N.4.3. Single Indicating Element/Multiple Indications. – In the case of an analog indicating 

element equipped with two or more indicating means within the same element, the difference in the weight 

indications for any load other than zero shall not be greater than one-half the value of the verification scale 

division (e) (d) and be within tolerance limits.

(Amended 1986)

The reference to tolerances in T.N.3.4. and T.N.4.3. should follow the principle of expressing tolerances in 

e. 

Group 4. Changes to clarify appropriate application of tolerances (Unmarked Scales)

T.1. General. – The tolerances applicable to devices not marked with an accuracy class shall have the 

tolerances applied as specified in Table T.1.1. Tolerances for Unmarked Scales. 

Note: When Table T.1.1. refers to T.N. sections it shall be accepted that the scale division d on the 

unmarked scale always equals the verification scale division e.

(Amended 20XX)

Prior to 1984, tolerances were based on percentage of load for most scales. There was no concept of 

verification scale division e. In the T.N. section all tolerances are expressed in e. The note is added to 

clarify that d for the T. section is always equal to e from the T.N. section.
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The work group noted that several specific paragraphs in the T. section for unmarked scales refer to 

tolerances in terms of d. Those sections are shown below. With the addition of the note to T.1. General, it 

was decided that it was not appropriate or necessary to change the d to e in these paragraphs.

T.2.2. General. – Except for scales specified in paragraphs T.2.3. Prescription Scales through T.2.8. 

Railway Track Scales: 2 d, 0.2 % of the scale capacity, or 40 lb, whichever is least.

T.2.4.2. With More Than One-Half Ounce Capacity. – 1 d or 0.05 % of the scale capacity, whichever 

is less.

T.2.7. Vehicle, Axle-Load, Livestock, and Animal Scales.

T.2.7.1. Equipped With Balance Indicators. – 1 d.

T.2.7.2. Not Equipped With Balance Indicators. – 2 d or 0.2 % of the scale capacity, whichever is 

less.

T.2.8. Railway Track Scales. – 3 d or 100 lb, whichever is less.

Group 5. Changes to clarify appropriate scale selection (reference Table 8)

Table 8.

Recommended Minimum Load

Class

Value of Verification Scale Division 

“e”

(d or e*)

Recommended Minimum Load in 

scale divisions “d” (See notes) (d 

or e*)

I equal to or greater than 0.001 g 100

II 0.001 g to 0.05 g, inclusive 20

equal to or greater than 0.1 g 50

III All** 20

III L All 50

IIII All 10

*For Class I and II devices equipped with auxiliary reading means (i.e., a rider, a vernier, 

or a least significant decimal differentiated by size, shape or color), the value of the 

verification scale division “e” is the value of the scale division immediately preceding the 

auxiliary means. For Class III and IIII devices the value of “e” is specified by the 

manufacturer as marked on the device; “e” must be less than or equal to “d.”

The displayed scale division d is not always equal to the verification scale division e. To ensure 

the correct values are used, refer to required markings on the device (see also notes 3 and 4 

in Table S.6.3.b.). 

For an ungraduated device, the scale division d shall be replaced with the verification scale 

division e in the last column.

**A minimum load of 10 d 5 e is recommended for a weight classifier marked in accordance 

with a statement identifying its use for special applications.
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In the header, the change in column 2 references e and the change in column 3 references d and directs you 

to the notes. Currently, the Code references (d or e) in both columns which causes confusion. We’re never 

sure which one to use. The justification for d in the last column follows below. 

It is vital to understand that Table 8. is tied closely to Table 3. You will find that header to the first two 

columns in both tables, with these changes, will be identical. The work group also revised the * note to 

remove the * and use parallel text to revised note 1 of Table 3. The notes section contains two special 

exceptions to the general values in column 3 the table. The first directs you to use e in the last column for 

ungraduated instruments, as these have no d values. The second directs you to use a minimum load of 5 e 

for weight classifiers. This aligns the value with R76. Note that the use of d for weight classifiers leads to 

unusual situations. Two weight classifiers with 100 lb capacity and e of 0.05 lb should have the same 

minimum load. However, they might have very different d values, say 1 lb and 0.2 lb. Declaring minimum 

load as 10 d for these result in very large differences of 10 lb minimum load for the first instrument and 2 

lb for the second. Since e < d for weight classifiers, the minimum load is correctly expressed in e. 

Understanding Minimum Load

In R76, minimum load “Min” is included in the principles of classification, see 2.2. below. There are 4 

mandatory markings; Class, Max, Min and e. When R76 was translated into HB 44 a conscious decision 

was made to remove Min from the classification and make it a user requirement. Thus, HB 44 only has 3 

mandatory markings; Class, Capacity, and d. We have already proposed to change the d to e above.

In R76, the issue of instrument accuracy is focused on Class, Max and e, parallel to HB 44. Absolute 

accuracy in terms of e and relative accuracy in terms of n. When the load is very small, i.e. less than Min, 

it might appear that R76 is addressing the large relative errors resulting in 1 e tolerance for some small 

number of e in load. However, this is not the case. The distinction is that Min applies to use of the 

instrument and not to testing of the instrument.

In testing under R76 tolerances, rounding errors are eliminated (see 3.5.3.2.). In practice this usually means 

error weights are used to resolve the instrument errors to at least 0.2 e (NTEP generally uses 0.1 e). In 

addition, R76 expects that instrument divisions are relatively uniform throughout the series. In order to get 

a +1 e error at 1 e load and still meet the requirement that the zero division be +/- 0.5 division wide, would 

require the 1 e divisions be 0 e wide (i.e. be skipped). To visualize in analog, imagine an indicator that 

starts at zero and jumps immediately to the 2 graduation. A load of 1 e would indicate 2 e. Likewise a load 

of 2 e would indicate 3 e and this pattern would repeat until the tolerance breakpoint, a load of 500 e would 

indicate 501 e. Then the second graduation after the break point would be skipped, i.e. the 502 e graduation. 
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A load of 501 e would indicate 503 e with a +2 e error. All the loads up to 20,000 e would now show a 

+2 e error. Instruments obviously should not, and DO NOT, operate that way.

If we assume instrument divisions are uniform, as R76 does, then the divisions should be accurate to about 

the relative % of the accuracy class. For Class II in the first step this is 0.02 %. Thus at 20 e load the 

maximum expected error (after eliminating rounding) should be in the order of 0.004 e, and not the 1 e 

permitted in the tolerance structure. So, what relative error can R76 be addressing when dealing with Min?

When an instrument is used in commerce, it is the rounding of the indication to 1⁄2 scale division that results 

in large relative errors. Consider a cannabis sale of 1.05 g when the division size is 0.1 g. The instrument 

must round off to either 1.0 g or 1.1 g. Either one produces an error in the weighment of 0.05 g. That’s 4.8

% relative error in the weighment (0.05 g / 1.05 g) with an instrument that’s supposed to be accurate to 0.02

%. It is this rounding error “in use” that produces the large relative errors addressed in Min in R76 and the 

minimum load in HB 44. This rounding error is a function of d, the displayed scale division, and not e. It 

is not a tolerance issue.

The confusion comes from the presentation of Min in terms of e in the last column of R76 Table 3. The 

table in R76 has an additional column for Min not found in HB 44. In HB 44 it has been relocated to 

Table 8. Looking closely at Table 8, you will find that the first two columns correspond to the first two 

columns in Table 3 in HB 44. So why does R76 express this column in e instead of d? I suspect they did 

it because all other values in Table 3 are in e. For instruments where e = d, the issue is moot. Note however, 

that R76 reveals the ties to d for the Class I and II instruments with an auxiliary indicating device 

(differentiated least significant digit). In 3.4.3. R76 directs that d replace e in the Min column of Table 3 

for instruments with an auxiliary indicating device.

On an instrument where e = 10 d, we can create the same scenario as before but now with a load of 1.005 g. 

The instrument must now round to either 1.00 g or 1.01 g. The rounding error is now 0.50 % of the 

weighment (0.005 / 1.005). That is 10 times smaller at the same 20 e load.

Returning to the four types of instruments from revised S.1.2.2. and applying revised Table 8.:

1. Graduated without an auxiliary indicating device: minimum load in d

2. Graduated with an auxiliary indicating device: minimum load in d

3. Graduated and marked for special use (weight classifier): minimum load 5 e

4. Ungraduated (equal arm scales): minimum load in e

Group 6. Changes to correctly reference to e or d as appropriate.

S.1.1.1. Digital Indicating Elements.

(a) A digital zero indication shall represent a balance condition that is within ± 1⁄2 the value of the 

verification scale division.

(b) A digital indicating device shall either automatically maintain a “center-of-zero” condition 

to ± 1⁄4 verification scale division or less, or have an auxiliary or supplemental “center-ofzero” indicator that defines a zero-balance condition to ± 1⁄4 of a verification scale division 
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or less. A “center-of-zero” indication may operate when zero is indicated for gross and/or 

net mode(s).

[Nonretroactive as of January 1, 1993]

 (c) For electronic cash registers (ECRs) and point-of-sale systems (POS systems) the display of 

measurement units shall be a minimum of 9.5 mm (3

/8 inch) in height. 

[Nonretroactive as of January 1, 2021]

(Added 2019)

(Amended 1992, 2008, and 2019, and 20XX) 

The changes correctly reference e in this section as this is an issue of ensuring the zero indication is accurate 

to 1⁄4 e. Hence it is a tolerance properly expressed in terms of e.

T.N.9. Radio Frequency Interference (RFI) and Other Electromagnetic Interference Susceptibility.

– The difference between the weight indication due to the disturbance and the weight indication without 

the disturbance shall not exceed one verification scale division (d) (e); or the equipment shall:

(a) blank the indication; or

(b) provide an error message; or

(c) the indication shall be so completely unstable that it cannot be interpreted, or transmitted into 

memory or to a recording element, as a correct measurement value.

The tolerance in T.N.9. Radio Frequency Interference (RFI) and Other Electromagnetic Interference 

Susceptibility is to be applied independently of other tolerances. For example, if indications are at allowable 

basic tolerance error limits when the disturbance occurs, then it is acceptable for the indication to exceed 

the applicable basic tolerances during the disturbance. 

(Amended 1997 and 20XX) 

This is a tolerance for reaction to a disturbance and is properly expressed in e. 

Group 7. Identify appropriate application of code sections (in order of appearance) 

When the paragraph references d it is referring to the actual scale division and the concern is how the 

instrument operates. When the paragraph references e it is referring to the verification scale division and 

the concern is in classification of the instrument or in accuracy of the displayed values. 

The sections in the table below currently correctly reference e or d as appropriate. The text of each section 

is not included for brevity. The justification may help explain the general rules above.

Code 

Section

Applies to Justification

G-S.5.2.2.(c) d Rounding is a function of instrument operation not accuracy

G-S.5.2.2.(d) d Requires “d” to be an indicated zero and all digits to the left of “d” to 

be zero when d<1.
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Code 

Section

Applies to Justification

Requires “d” to be an indicated zero and all digits to the right of “d” to 

be zero when d>5.

S.1.2. d 1, 2, or 5 refers to d which is rounded. When e ≠ d refer to section 

S.1.2.2. for value of e.

S.1.2.1 d Refers to rounded values of d.

S.1.2.3. e This is a classification issue. It ensures accuracy of the piece counts.

S.1.7.(b) e This is a classification issue addressing maximum indication above 

capacity.

S.2.1.2. d They must be in terms of d since stability of zero setting applies to d.

S.2.1.3.(all) d These limit the window for action of AZT. They must be in terms of d 

since zero setting applies to d.

S.2.3. d Tare division must equal smallest increment displayed.

T.N.7. d Discrimination requires an instrument to discriminate to the displayed 

scale division (zone of uncertainty). This relates to the rounding of the 

smallest increment.

UR.3.7. d Minimum load is correctly expressed in d. (see Group 5 above)

UR.3.10. e As written, this is clearly e. (See issues for additional study)

PART 3. Issues Identified as Requiring Additional Study (outside the scope of this workgroup)

A. The work group was in consensus that we should expand requirements in S.2.1.2. relating to semiautomatic zero to apply to all scales and not just scales used in direct sale. In first place, suitability is a 

User Requirement and not a specification. Second, correct operation to set zero should be applicable to all 

digital instruments as it is in R76.

B. The application of tolerances to net loads has always been assumed, even before the Scales Code 

adoption in 1984. Comparing T.2. for unmarked scales and T.N.2.1. for marked scales reveals important 

differences particularly regarding net loads. As written, T.N.2.1. exempts calculated net, but it appears to 

apply to both semi-automatic tare and preset tare. A comparison to R76 shows that OIML limits 

applicability of tolerances. Their MPE’s do not apply to calculated net values or when preset tare (keyboard 

or programmed tare) is in operation (section 2.2). It appears net loads have MPE’s applied only when the 

net zero is set in compliance with S.1.1.1.(b) which requires accuracy of zero to 1⁄4 division. This cannot 

be assured with preset tare or when net is based on two gross values. This has further ramifications to any 

case where all three (gross, tare and net) values are indicated/recorded for a transaction. OIML requires 

the gross and net weights be accurate but does not apparently require that the equation gross – tare = net be 

in mathematical agreement due to rounding issues. Note that in most transactions, the customer only gets 

one or two of the gross, tare or net values. Rounding issues do not arise for this reason. This may impact a 

current issue before NCWM dealing with printing tare on POS transaction receipts. Consider a POS 

transaction where the customer saw 1.02 lb on the weight display and sees 1.00 lb net and 0.03 lb tare. 

These are all accurate weights (and correct per R76) but the numbers don’t’ add up. The customer will 

claim they were overcharged by 0.01 lb since 1.02 lb – 0.03 lb = 0.99 lb.

C. The resolution of errors in testing scales was identified as an issue. The original proposal included a 

revision requiring resolution of error to at least 0.2 e. R76 specifically declares that errors be resolved to at 
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least 0.2 e to eliminate rounding error. HB 44 has no such provision and it might appear that rounding error 

is included in the tolerance. Instead of tolerance steps of 1, 2, etc., it could be argued that the tolerances 

are 1.5, 2.5, etc. as the result of direct reading. NTEP uses the R76 approach exclusively in testing, but it 

has no technical basis in the Code. There are obvious issues involved in using error weights in the field. 

The challenge is that you either eliminate rounding in determining tolerances or you don’t. We have two 

standards at play at present. In addition, it can be argued that Class IIIL instruments are already high 

resolution somewhat similar to Class I and II instrument with e >d. Class IIIL devices have enough 

resolution to read errors to 0.2 e or 0.1 e of the equivalent Class III instrument without using error weight.

D. The UR.3.10. requirement that transactions from dynamic monorail scales be based on e raises issues. 

It was discussed since it involves both e and d. The displayed scale divisions equal to e (i.e. 10 d) are not 

normally rounded. If e = 10 d then the rounding point is not 5 up/4 down, as it is for d, but rather 9.5 up/0.5 

down. Does this requirement mean the scale design has to produce a properly rounded value for the 

transaction that may be different from the display, e.g. 943.7 lb to d of 0.1 lb now must be recorded for the 

transaction as 944 lb? In addition, in brief discussion, it seemed there were many ways this could be 

interpreted. The workgroup concluded it would be beneficial to open some discussions with USDA and 

the manufacturers to explores some of these questions. This also addresses similar issues to the proposal 

to delete S.1.2.2.2. where questions of using e or d are impacting high precision scales in cannabis and 

jeweler’s sales.

ITEM BLOCK 3 (B3) D TOLERANCES FOR DISTANCE TESTING IN TAXIMETERS AND 

TRANSPORTATION NETWORK SYSTEMS

B3: TXI-20.1 D T. Tolerances

B3: TNS-20.1 D T. Tolerances

Source: New York Department of Agriculture and Markets

Purpose and Justification: 

Provide the same distance-measurement tolerances for the Taximeters Code and Transportation Network 

Systems Code.

OWM Executive Summary for Item Block 3 (B3) – Tolerances for Distance Testing in 

Taximeters and Transportation Network Systems

OWM Recommendation: OWM concurs with the three regional weights and measures associations that

recommended additional development on this item. OWM continues to encourage the submitter to work 

with the USNWG and others to ensure that the modified proposal fully considers the technology used in 

TNMS as noted in the summary below.

• The submitters' March 2022 alternate proposal would permit a dual tolerance structure for vehicles 

within a single company or operating in the same geographic area. 

• Work may need to be stepped up to address issues identified in the areas of design and function of 

indicating elements, provisions for sealing, and location services signal loss so that these provisions 

are in the code for properly operating this newer technology in taxis.
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Table 3. Summary of Recommendations

Item B3: TXI-20.1 D T. Tolerances

V D W A I Notes* Comments

Submitter  1 Submitted modified proposal 3/23/22.

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

 1 Recommendation based on the submitter’s

March 2022 modifications to the proposal.

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 - Submitted modified language

2 - Item not discussed

3 - No meeting held

4 - Not submitted on agenda

 5 - No recommendation or not considered

Item under Consideration:

The Item under Consideration published in the Committee’s 2022 Interim Report is shown below. 

B3: TXI-20.1 D T. Tolerances

Amend Handbook 44, Taximeters Code as follows. 

T. Tolerances

T.1. Tolerance Values.

T.1.1. On Distance Tests. – Maintenance and acceptance tolerances for taximeters shall be as 

follows:

(a) On Overregistration: 1 % of the interval under test when the distance is 1.6 km (1 mile) or less. 2.5 

% of the interval under test when the distance is greater than 1.6 km (1 mile). 
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B3: TNS-20.1 D T. Tolerances

Amend Handbook 44, Transportation Network Systems Code as follows:

T. Tolerances

T.1.1. Distance Tests. – Maintenance and acceptance tolerances shall be as follows:

(a) On Overregistration: 2.5 % 1 % of the interval under test when the distance is 1.6 km 

(1 mile) or less. 2.5 % of the interval under test when the distance is greater than 1.6 

km (1 mile).

(b) On Underregistration: 2.5 % 4 % of the interval under test.

On March 23, 2022, the submitter requested the Committee replace the Item under Consideration shown in 

the 2022 S&T Interim Report with the following.

Modify NIST Handbook 44 Section 5.54 Taximeters Code as follows:

T.1. Tolerance Values.

T.1.1. On Distance Tests. – Maintenance and acceptance tolerances for taximeters shall be as 

follows:

T.1.1.1. Meters Using Distance generated from sources physically connected to the 

vehicle (e.g OBD sensor).

(a) On Overregistration: 1 % of the interval under test.

(b) On Underregistration: 4 % of the interval under test, with an added tolerance of 30 m 

or 100 ft whenever the initial interval is included in the interval under test.

T.1.1.2. Meters Using Distance generated from sources not physically connected to the 

vehicle (e.g navigation satellite system such as GPS and /or other location services).

(a) On Overregistration: 2.5 %

(b) On Underregistration: 2.5 %

Withdraw the TNMS portion of the original proposal and leave the existing TNMS Code as it currently 

appears in NIST Handbook 44.

NIST OWM Detailed Technical Analysis:

OWM appreciates the efforts of the submitter to harmonize the tolerance requirements in the Taximeters 

Code and the TNMS Code although, we do not believe it is necessary to increase the tolerance allowed 

since taximeters have been required to comply with the existing tolerances for decades. 
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OWM also notes that TNMS do not typically assess fare charges based on intervals as do taximeters. 

Taximeters will accumulate fare charges by summing the number of intervals comprising the trip’s distance 

traveled and time elapsed and multiplying by the appropriate rate. In contrast, TNMS typically base the 

fare charges on the total distance (and time in some cases) for the trip. For this reason, we do not believe 

it is necessary to amend paragraphs T.1.1.(a) and (b) to refer to “interval under test” as is shown in the 

proposal. OWM recommends that this proposal be further developed with the assistance of the NIST 

USNWG on Taximeters in such a way that will better align the HB 44 Taximeters and TNMS Codes.

The NIST led U.S. National Work Group (USNWG) on Taximeters has held virtual meetings in May, June, 

and October 2020 and June 2021 to further develop standards for both taximeters and TNMS. The focus 

of these meetings was the merger of the existing HB 44 Taximeters Code and the tentative TNMS Code. 

Those members attending these meetings were in general agreement that this is the appropriate direction 

the work group should take. The USNWG also began discussions on some of the areas to be addressed in 

a unified “Transportation-for-Hire Systems” Code that could present challenges in the development of 

appropriate requirements. Those areas included the design and function of indicating elements, provisions 

for sealing, and location services signal loss.

The submitter of the proposal (New York or NYS) has agreed to work with the USNWG to further develop 

this proposal and is actively participating in those meetings. The submitter explained to the USNWG that 

some of the more recent systems submitted to the state of New York for type approval have not been able 

to comply with the existing taximeter tolerances. This failure was seen in systems that attempted to use 

location services (i.e., GPS) to measure distance. In response to that point, it was noted that other systems 

have been able to meet those tolerances and to expand the tolerances would be an approach that is not 

supported by most in the weights and measures community.

Also included as a topic in the meetings was this proposal submitted to the NCWM S&T Committee to 

amend the HB 44 Taximeters and TNMS Codes. The USNWG agreed that the two HB 44 Codes should 

be merged and that this could be accomplished by continuing its efforts in the future.

NIST OWM is aware that the developer of the proposal was not able to provide updates to the proposal in 

January 2022 because of technical difficulties with audio-visual equipment at the NCWM Interim Meeting. 

The NYS alternate proposal modifies only the Taximeter Code tolerances and was made available on March 

23, 2022 on the NCWM website. This update was noted in the CWMA and NEWMA Annual Meeting 

summaries. The NYS alternate proposal establishes a new set of taximeter over- and under-registration 

tolerances at 2.5 % which are equivalent to those applied to TNMS. The current tolerances remain in place 

when the taximeter source for distance measurements is connected to the vehicle. The proposed new 

tolerances apply when the taximeter’s source for distance measurement is generated from equipment not 

physically connected to the vehicle such as a GPS. This mechanism for generating measurement data from 

sources not physically connected to the vehicle is similar in the operation of a TNMS.

On March 23, 2022, NYS also withdrew the portion of Block 3 designated as B3: TNS-20.1 T. Tolerances, 

and no longer recommends modifying Transportation Network Measurement Systems -Tentative Code 

paragraph T.1.1. Distance Tests maintenance and acceptance tolerances for over- and under-registration 

and to reestablish the limits of permissible error of the TNMS under test as a percentage of the interval 

under test and distance traveled over the test course.

Based on the methodology used to determine distance traveled the proposal would permit a dual tolerance 

structure for vehicles within a single company or operating in the same geographic area. Work may need 

to be stepped up to address issues identified in the areas of design and function of indicating elements, 
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provisions for sealing, and location services signal loss so that these provisions are in the code for properly 

operating this newer technology in taxis.

Summary of Discussions and Actions:

At the 2022 NCWM Interim Meeting, the Committee assigned a developing status for this item at the 2022 

Interim Meeting. The committee recommends the submitter work with the USNWG on this proposal. As 

noted in open hearings this is an item on the USNWG agenda and there may be efforts on the way to address 

this issue by other means.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Kurt Floren (Los Angeles County, California): This coincides with previous comments: new tech with 

GPS tracking and network companies are out. We are now taking age-old tech that's meeting 1 % tolerance 

and proposing to expand the tolerance (existing equipment has been meeting with no issues). He does not 

support this item until the data has been evaluated. He recommends this item to remain developmental until 

more data is available.

The WWMA S&T Committee recommends the status remain Developmental.

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the Committee heard no comments on this item. 

This committee recommends this item remain a Developing item so that the involved parties have more 

time to find a way to align the tolerances in the Handbook.

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Jim Willis commented to explain the relationship of the two systems. Taxi Meters vs Transportation 

Network Systems and the different tolerances that are applied. The tolerances are different in the HB 44 

and therefor when a taxi meter using satellite technology is used, the tolerance is tighter and therefore the 

playing field is not level.

Mr. Lou Sakin (Hopkinton/Northbridge, Massachusetts) asked if industry has commented or questioned 

this procedure. Jim Willis (New York) was not aware at the time. Lou Sakin (Hopkinton/Northbridge, 

Massachusetts) further commented that if the playing field is not level, then he recommends a Voting status. 

Ms. Juana Williams (NIST OWM) commented and recommended that the submitter work with the work 

group to fully develop the code. 

The NEWMA Specifications and Tolerances Committee recommends that this item be given Developing 

Status with continued involvement with the National Taxi Meter Work Group.
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During the 2022 Annual Meeting Open Hearing comments were heard from the floor. Mr. Jim Willis (New 

York) has submitted some updated language and asks that this item continue to be developing.

After hearing comments from the floor, the Committee recognized the need to further develop this block 

and recommended the block retain developing status. NEWMA recommends this proposal as a Developing 

Item on the NCWM agenda. 

Central Weights and Measures Association

During the 2021 Interim Meeting: The committee heard comments from the floor. Ms. Diane Lee (NIST) 

comments are in report on NCWM website.

CWMA S&T Committee recommends the item move forward as a developing item.

During the CWMA 2022 Annual Meeting limited questions were heard and an update to the proposal from 

the submitter. Charlie Stutesman (Kansas) – Interested to know why the tolerance isn’t consistent with 

underregistration and overregistration. The submitter of this item provided an updated proposal on March 

23, 2022, which is posted on the NCWM website. This update clarified the tolerances for TXI-20.1 and 

recommended withdrawal of TNS-20.1. 

The CWMA S&T Committee recommends withdrawal of TNS-20.1 per the submitter’s request. The 

Committee recommends that TXI-20.1 proceed to voting status as presented in the March 23, 2022, updated 

proposal:

T.1. Tolerance Values.

T.1.1. On Distance Tests. – Maintenance and acceptance tolerances for taximeters shall be as 

follows:

T.1.1.1. Meters Using Distance generated from sources physically connected to the 

vehicle (e.g., OBD sensor).

(a) On Overregistration: 1 % of the interval under test. 

(b) On Underregistration: 4 % of the interval under test, with an added tolerance of 30 m 

or 100 ft whenever the initial interval is included in the interval under test.

T.1.1.2. Meters Using Distance generated from sources not physically connected to the 

vehicle (e.g., navigation satellite system such as GPS and/or other location services).

(a) On Overregistration: 2.5 % 

(b) On Underregistration: 2.5 % 

CWMA recommends withdrawal of TNS-20.1 and that TXI-20.1 as modified be presented as a Voting Item 

on the NCWM agenda. 
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ITEM BLOCK 4 (B4) D ELECTRONICALLY CAPTURED TICKETS OR RECEIPTS

(Note: The Item under Consideration reflects changes that were received by the committee from the 

submitter of the item and that the Committee agreed to during its 2021 Interim Meeting work session. The 

changes are highlighted.)

B4: GEN-21.2 D G-S.5.6. Recorded Representations.

B4: LMD-21.2 D S.1.6.5. Money Value Computations., UR.3. Use of a Device.

B4: VTM-21.1 D S.1.1. Primary Elements., UR.2. User Requirements

B4: LPG-21.1 D S.1.1. Primary Elements., UR.2. User Requirements

B4: CLM-21.1 D S.1.4.1. Printed Ticket Recorded Representation., UR.2.6.3. Printed Ticket

Recorded Representation.

B4: MLK-XX-X D S.1.4.2 Printed Ticket Recorded Representation., UR.2.2. Printed Ticket, 

Recorded Representation.

B4: MFM-21.2 D S.6. Printer Recorded Representations., UR.2.6. Ticket Printer, Customer Ticket, 

Recorded Representation., UR.3.4. Printed Ticket. Recorded Representation.

B4: CDL-21.1 D S.1.4.1. Printed Ticket Recorded Representations., UR.2.4.2. Tickets or Invoices.

Recorded Representation.

B4: HGM-21.1 D S.2.6. Recorded Representations, Point of Sale Systems., S.6. Printer. Recording 

Element., UR.3.2. Vehicle-mounted Measuring Systems Ticket Printer Recording 

Element., UR.3.3. Printed Ticket. Recorded Representation.

B4: OTH-21.2 D Appendix D - Definitions.: recorded representations, recording element.

Source: Kansas Department of Agriculture, Division of Weights and Measures

Purpose and Justification:

Allow recorded values to be captured electronically as an alternative to a printed ticket or receipt.

In 2014 G-S.5.6. was added to Handbook 44 to allow for the issuance of electronic receipts. At that time 

the use of the term “print”, and all variations on the word “print” was not fully addressed.

The Oxford Dictionary defines print as “a mechanical process involving the transfer of text, images, or 

designs to paper.”

The Oxford Dictionary defines record as: to “set down in writing or some other permanent form for later 

reference, especially officially.”

Values that are delivered via electronic means are recorded values and not necessarily printed vales. Printed 

indicates that a value has been transferred on to a hard document. While the intent of the 2014 amendment 

was to allow for the use of electronic receipts the terminology used is incorrect. In addition to receipts, 

there are instances where other information may be transmitted electronically.

When applying G-A.2. to weighing and measuring devices,

G-A.2. Code Application. – This General Code shall apply to all classes of devices as covered in 

the specific codes. The specific code requirements supersede General Code requirements in all cases 

of conflict.

(Amended 1972) 
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Multiple conflicts arise in the implementation of the 2014 Amendment of G-S.5.6. This is to clarify the 

terminology in Handbook 44 and to recognize the changing technology in how transactions are recorded, 

and the information is disseminated.

OWM Executive Summary for Item Block 4 (B4) – Electronically Captured Tickets or 

Receipts 

OWM Recommendation: Although NIST OWM feels that all proposed changes would benefit from 

additional review, NIST OWM believes that the additional changes made to G-S.5.6 provides clarity. 

NIST OWM believes a Developing status is appropriate so that changes to the B4 specific codes are 

carefully reviewed to ensure the proposed changes do not change the original intent of the specific section 

before moving these items forward for a vote. 

• Most of the changes proposed by NIST OWM are included in the proposal, except for the 

recommendation that “However” be removed from the General Code requirement in this proposal. 

We recommend that “However” be removed.

Table 3. Summary of Recommendations

Item Block 4 – Electronically captured tickets or receipts

V D W A I Notes* Comments

Submitter 

• Proposed Revisions by Submitter (09-28-

2020)

• Further Comments (01-13-2021)

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered
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Item under Consideration:

B4: GEN-21.2 D G-S.5.6. Recorded Representations.

Amend Handbook 44, General Code as follows: 

G-S.5.6. Recorded Representations. – Insofar as they are appropriate, the requirements for 

indicating and recording elements shall also apply to recorded representations. All recorded values 

shall be printed provided presented digitally. In applications where recorded representations are

required by a specific code, the customer may be given the option of not receiving the recorded 

representation. Unless otherwise specified, recorded representations referenced in specific codes 

shall be made available to the customer as a minimum in hard copy form. However, for systems 

equipped with the capability of issuing an electronic receipt, ticket, or other recorded representation, 

the customer may be given the option to receive any required information electronically (e.g., via cell 

phone, computer, etc.) in lieu of or in addition to a hard copy.

(Amended 1975, 2014 and 20XX) 

B4: LMD-21.2 D S.1.6.5. Money Value Computations., UR.3. Use of a Device.

Amend Handbook 44, Liquid Measuring Devices Code as follows: 

S.1.6.5. Money-Value Computations

... 

S.1.6.5.6. Display of Quantity and Total Price, Aviation Refueling Applications.

(a) The quantity shall be displayed throughout the transaction.

(b) The total price shall also be displayed under one of the following conditions:

(1) The total price can appear on the face of the dispenser or through a controller adjacent 

to the device.

(2) If a device is designed to continuously compute and display the total price, then the 

total price shall be computed and displayed throughout the transaction for the quantity 

delivered.

(c) The total price and quantity shall be displayed for at least five minutes or until the next 

transaction is initiated by using controls on the device or other customer-activated 

controls.

(d) A printed receipt shall be available and shall include, at a minimum, the total price, 

quantity, and unit price.

[Nonretroactive as of January 1, 2008]

(Added 2007) (Amended 20XX)

S.1.6.7. Recorded Representations. – Except for fleet sales and other price contract sales and for 

transactions where a post-delivery discount is provided, a printed receipt providing the following 
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information shall be available through a built-in or separate recording element for all transactions 

conducted with point-of-sale systems or devices activated by debit cards, credit cards, and/or cash:

(a) the total volume of the delivery;*

(b) the unit price;*

(c) the total computed price;*

(d) the product identity by name, symbol, abbreviation, or code number;* and

(e) the dispenser designation by either an alphabetical or numerical description.**

*[Nonretroactive as of January 1, 1986] **[Nonretroactive as of January 1, 2021]

(Added 1985) (Amended 1997, 2012, 2014, 2018 and 20XX) 

S.1.6.8. Recorded Representations for Transactions Where a Post-Delivery Discount(s) is 

Provided. – Except for fleet sales and other price contract sales, a printed receipt providing the 

following information shall be available through a built-in or separate recording element that is part of 

the system for transactions involving a post-delivery discount:

(a) the product identity by name, symbol, abbreviation, or code number;

(b) transaction information as shown on the dispenser at the end of the delivery and prior to any 

post-delivery discount(s), including the: 

(1) total volume of the delivery; 

(2) unit price; and 

(3) total computed price of the fuel sale.

(c) an itemization of the post-delivery discounts to the unit price; 

(d) the final total price of the fuel sale after all post-delivery discounts are applied; and

(e) the dispenser designation by either an alphabetical or numerical description.

[Nonretroactive as of January 1, 2021]

(Added 2012) (Amended 2014, and 2018, and 20XX) 

... 

UR.3. Use of a Device

... 

UR.3.3. Computing Device – Any computing device used in an application where a product or 

grade is offered for sale at one or more unit prices shall be used only for sales for which the device 

computes and displays the sales price for the selected transaction.

(Became retroactive 1999)

(Added 1989) (Amended 1992)
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The following exceptions apply:

(a) Fleet sales and other price contract sales are exempt from this requirement.

(b) A truck stop dispenser used exclusively for refueling trucks is exempt from this requirement 

provided that:

(1) all purchases of fuel are accompanied by a printed receipt of the transaction containing 

the applicable price per gallon, the total gallons delivered, and the total price of the sale; 

and

(Added 1993)

(2) unless a dispenser complies with S.1.6.4.1. Display of Unit Price, the price posted on the 

dispenser and the price at which the dispenser is set to compute shall be the highest price 

for any transaction which may be conducted.

(Added 1993)

(c) A dispenser used in an application where a price per unit discount is offered following the 

delivery is exempt from this requirement, provided the following conditions are satisfied:

(1) the unit price posted on the dispenser and the unit price at which the dispenser is set to 

compute prior to the application of any discount shall be the highest unit price for any 

transaction;

(Amended 2014)

(2) all purchases of fuel are accompanied by a receipt recorded by the system. The receipt 

shall contain:

a. the product identity by name, symbol, abbreviation, or code number;

b. transaction information as shown on the dispenser at the end of the delivery and prior 

to any post-delivery discount including the:

1. total volume of the delivery; 

2. unit price; and 

3. total computed price of the fuel sale prior to post-delivery discounts being applied.

c. an itemization of the post-delivery discounts to the unit price; and 

d. the final total price of the fuel sale.

(Added 2012) (Amended 2014)

(Added 1989) (Amended 1992, 1993, 2012, and 2014, and 20XX) 

UR.3.4. Printed Ticket. Recorded Representation. – The total price; the total volume of the 

delivery; the price per liter or gallon; and a corresponding alpha or numeric dispenser designation*

shall be shown, either printed recorded by the device or in clear hand script, on any printed ticket

issued by a device and recorded representation containing any one of these values and shall comply 
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with G-S.5.6. Establishments where no product grades are repeated are exempt from the dispenser 

designation requirement.

*[Nonretroactive as of January 1, 2021]

(Amended 2001, 2018, and 2019, and 20XX) 

B4: VTM-21.1 D S.1.1. Primary Elements., UR.2. User Requirements

Amend Handbook 44, Vehicle Tank Meter Code as follows: 

S.1.1. Primary Element

S.1.1.1. General. – A meter shall be equipped with a primary indicating element. and may also 

be equipped with a primary recording element. Except for systems used solely for the sale of 

aviation fuel into aircraft and for aircraft-related operations, a meter shall be equipped with 

a primary recording element.

(Amended 1993 and 20XX) 

Note: Except for systems used solely for the sale of aviation fuel into aircraft and for aircraftrelated operations, vehicle-tank meters shall be equipped with a primary recording element 

as required by paragraph UR.2.2. Ticket Printer; Customer Ticket. Recorded 

Representation

(Amended 1993 and 20XX) 

... 

S.1.4.2. Printed Ticket. Recorded Representation. – If a computing-type device issues a printed 

ticket recorded representation which displays the total computed price, the ticket recorded 

representation shall also have printed clearly thereon record the total quantity of the delivery, 

the appropriate fraction of the quantity, and the price per unit of quantity.

(Amended 1989, and 20XX) 

... 

UR.2. User Requirements.

... 

UR.2.2. Ticket Printer, Customer Ticket Recording Element. – Vehicle-Mounted metering 

systems shall be equipped with a ticket printer which shall be used for means to record all sales 

where product is delivered through the meter and shall comply with G-S.5.6. A copy of the ticket 

issued by the device shall be left with provided to the customer at the time of delivery or as otherwise 

specified by the customer.

(Added 1993) (Amended 1994, and 20XX) 

B4: LPG-21.1 D S.1.1. Primary Elements., UR.2. User Requirements

Amend Handbook 44, LPG and Anhydrous Ammonia Liquid-Measuring Devices Code as follows: 

S.1.1. Primary Elements. 
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S.1.1.1. General. – A meter shall be equipped with a primary indicating element and may also be 

equipped with a primary recording element.

Note: Vehicle-mounted metering systems shall be equipped with a primary recording element as 

required by paragraph UR.2.6. Ticket Printer; Customer Ticket.Recorded Representation

(Amended 20XX)

...

S.1.1.6. Printed Ticket. Recorded Representation – Any printed ticket issued recorded 

representation created by a device of the computing type on which there is printed includes the 

total computed price, shall have printed clearly also include thereon the total volume of the 

delivery in terms of liters or gallons, and the appropriate decimal fraction of the liter or gallon, and 

the corresponding price per liter or gallon.

(Added 1979) (Amended 1987, and 20XX) 

... 

S.1.5.5. Recorded Representations for Transactions Where a Post-Delivery Discount(s) is 

Provided. – Except for fleet sales and other price contract sales, a printed receipt recorded 

representation providing the following information shall be available through a built-in or separate 

recording element that is part of the system for transactions involving a post-delivery discount:

(a) the product identity by name, symbol, abbreviation, or code number;

(b) transaction information as shown on the dispenser at the end of the delivery and prior to 

any post-delivery discount(s), including the:

(1) total volume of the delivery;

(2) unit price; and

(3) total computed price of the fuel sale.

(c) an itemization of the post-delivery discounts to the unit price; and

(d) the final total price of the fuel sale after all post-delivery discounts are applied.

(Added 2016) (Amended 20XX)

... 

UR.2. User Requirements.

... 

UR.2.6. Ticket Printer, Customer Ticket. Recorded Representation– Vehicle-Mounted 

metering systems shall be equipped with a ticket printer which shall be used for means to record 

all sales where product is delivered through the meter and shall comply with G-S.5.6. A copy of the 

ticket recorded representation issued by the device shall be left with provided to the customer at the 

time of delivery or as otherwise specified by the customer.
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(Added 19932) (Amended 1994, and 20XX) 

... 

UR.2.7.2. Computing Device. – Any computing device used in an application where a product or 

grade is offered for sale at one or more unit prices shall be used only for sales for which the device 

computes and displays the sales price for the selected transaction. The following exceptions apply:

(a) Fleet sales and other price contract sales are exempt from this requirement.

(b) A truck stop dispenser used exclusively for refueling trucks is exempt from this 

requirement provided that:

(1) all purchases of fuel are accompanied by a printed receipt recorded representation 

of the transaction containing the applicable price per unit of measure, the total quantity 

delivered, and the total price of the sale; and

(2) unless a dispenser complies with S.1.5.1. Display of Unit Price, the price posted on the 

dispenser and the price at which the dispenser is set to compute shall be the highest 

price for any transaction which may be conducted.

(c) A dispenser used in an application where a price per unit discount is offered following the 

delivery is exempt from this requirement, provided the following conditions are satisfied:

(1) the unit price posted on the dispenser and the unit price at which the dispenser is set to 

compute shall be the highest unit price for any transaction;

(2) all purchases of fuel are accompanied by a receipt recorded by the system for the 

transaction containing:

a. the product identity by name, symbol, abbreviation, or code number;

b. transaction information as shown on the dispenser at the end of the delivery and 

prior to any post-delivery discount including the:

1. total volume of the delivery;

2. unit price; and

3. total computed price of the fuel sale prior to post-delivery discounts being 

applied.

c. an itemization of the post-delivery discounts to the unit price; and

d. the final total price of the fuel sale after all post-delivery discounts are applied.

(Added 2016) (Amended 20XX)
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B4: CLM-21.1 D S.1.4.1. Printed TicketRecorded Representation., UR.2.6.3. Printed 

TicketRecorded Representation.

Amend Handbook 44, Cryogenic Liquid-Measuring Devices Code as follows: 

S.1.4.1 Printed Ticket Recorded Representation –Any printed ticket recorded representation 

issued by a device of the computing type on which there is printed includes the total computed price

shall have printed clearly thereon also include the total quantity of the delivery, and the price per 

unit.

(Amended 20XX) 

And

UR.2.6.2. Tickets or Invoices. Recorded representation– Any written invoice, or printed ticket,

recorded representation based on a reading of a device that is equipped with an automatic temperature 

or density compensator shall have shown thereon that the quantity delivered has been adjusted to the 

quantity at the NBP of the specific cryogenic product or the equivalent volume of gas at NTP.

(Amended 20XX)

UR.2.6.3. Printed Ticket. Recorded Representation. – Any printed ticket issued recorded 

representation provided by a device of the computing type on which there is printed includes the 

total computed price, the total quantity of the delivery, or the price per unit, shall also show include 

the other two values. (either printed or in clear hand script).. and shall comply with G-S.5.6. 

(Amended 20XX)

B4: MLK-21.1 D S.1.4.2. Printed Ticket Recorded Representation., UR.2.6.3. Printed 

TicketRecorded Representation.

Amend Handbook 44, Milk Meter Code as follows: 

S.1.4.2. Printed Ticket Recorded Representation – If a computing-type device issues a printed 

ticket recorded representation which displays includes the total computed price, the ticket

recorded representation shall also have printed clearly thereon include the total quantity of the 

delivery, the appropriate fraction of the quantity, and the price per unit of quantity.

(Amended 1989, and 20XX) 

UR.2.2. Printed Ticket. Recorded Representation. – Any printed ticket issued recorded 

representation created by a device of the computing type on which there is printed includes the total 

computed price, the total quantity, or the price per unit of quantity, shall also show include the other 

two values (either printed or in clear hand script). and shall comply with G-S.5.6. 

(Amended 1989 and 20XX)

B4: MFM-21.2 D S.6. PrinterRecorded Representations., UR.2.6. Ticket Printer, Customer 

Ticket, Recorded Representation., UR.3.4. Printed Ticket. Recorded 

Representation.

Amend Handbook 44, Mass Flow Meter Code as follows: 
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S.6.Printer. Recording Element – When an assembly is equipped with means for printing recording

the measured quantity, the following conditions apply:

(a) the scale interval shall be the same as that of the indicator;

(b) the value of the printed recorded quantity shall be the same value as the indicated quantity;

(c) the printed recorded quantity shall also include the mass value if the mass is not the indicated 

quantity;

[Nonretroactive as of January 1, 2021]

(d) a quantity for a delivery (other than an initial reference value) cannot be recorded until the 

measurement and delivery has been completed;

(e) the printer recording element is returned to zero when the resettable indicator is returned to 

zero; and

(f) the printed recorded values shall meet the requirements applicable to the indicated values.

(Amended 2016, and 20XX) 

S.6.1. Printed Receipt Recorded Representations. – Any When a quantity is delivered, 

printed quantity the recorded representation shall include an identification number, the time and 

date, and the name of the seller. This information may be printed by the device or pre-printed on 

the ticket.

(Amended 20XX)

And

UR.3.3 Ticket Printer, Customer Ticket, Recorded Representation. – Vehicle-Mounted 

metering systems shall be equipped with a ticket printer which shall be used for means to record 

all sales where product is delivered through the meter and shall comply with G-S.5.6. A copy of 

the ticket recorded representation issued by the device shall be left with provided to the customer 

at the time of delivery or as otherwise specified by the customer.

(Added 19934) (Amended 20XX) 

... 

UR.3.4.Printed Ticket. Recorded Representation. – The total price, the total quantity of the 

delivery, and the price per unit shall be printed provided on any ticket recorded representation

issued by a device of the computing type and containing any one of these values.

(Added 1993) (Amended 20XX) 

B4: CDL-21.1 D S.1.4.1. Printed TicketRecorded Representations., UR.2.4.2. Tickets or Invoices. 

Recorded Representation.

Amend Handbook 44, Carbon Dioxide Liquid-Measuring Devices Code as follows: 
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S.1.4.1. Printed Ticket. Recorded Representation– Any printed ticket recorded representation

issued by a device of the computing type on which there is printed includes the total computed price 

shall have printed clearly thereon also include the total quantity of the delivery and the price per unit.

(Amended 20XX)

UR.2.4.2. Tickets or Invoices Recorded Representation. – Any written invoice or printed ticket

recorded representation based on a reading of a device that is equipped with an automatic temperature 

or density compensator shall have shown thereon include that the quantity delivered has been 

temperature or density compensated.

(Amended 20XX) 

B4: HGM-21.1 D S.2.6. Recorded Representations, Point of Sale Systems., S.6. Printer. 

Recording Element., UR.3.2. Vehicle-mounted Measuring Systems Ticket 

Printer Recording Element., UR.3.3. Printed Ticket. Recorded 

Representation.

Amend Handbook 44, Hydrogen Gas-Measuring Devices Code as follows: 

S.2.6. Recorded Representations, Point of Sale Systems. – A printed receipt shall be available 

through a built-in or separate recording element for transactions conducted with point-of-sale systems 

or devices activated by debit cards, credit cards, and/or cash. The printed receipt shall contain the 

following information for products delivered by the dispenser:

(a) the total mass of the delivery;

(b) the unit price;

(c) the total computed price; and

(d) the product identity by name, symbol, abbreviation, or code number.

(Amended 20XX)

... 

S.6. Printer. Recording Element – When an assembly is equipped with means for printing recording

the measured quantity, the printed recorded information must agree with the indications on the dispenser 

for the transaction and the printed recorded values shall be clearly defined.

(Amended 20XX)

S.6.1. Printed Receipt. Recorded Representation – Any When a quantity is delivered, printed 

quantity the recorded representation shall include an identification number, the time and date, and 

the name of the seller. This information may be printed by the device or pre- printed on the ticket.

(Amended 20XX)

And

UR.3.2. Vehicle-mounted Measuring Systems Ticket Printer Recording Element. 

(Amended 20XX) 
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UR.3.2.1. Customer Ticket Recording Element. – Vehicle-Mounted metering systems shall be 

equipped with a ticket printer which shall be used for means to record all sales where product 

is delivered through the device and shall comply with G-S.5.6. A copy of the ticket recorded 

representation issued by the device shall be left with provided to the customer at the time of 

delivery or as otherwise specified by the customer.

(Amended 20XX) 

... 

UR.3.3. Printed Ticket. Recorded Representation. – The total price, the total quantity of the 

delivery, and the price per unit shall be printed provided on any ticket recorded representation

issued by a device of the computing type and containing any one of these values.

(Added 1993) (Amended 20XX)

B4: OTH-21.2 D Appendix D - Definitions.: recorded representations, recording element.

Amend Handbook 44, Appendix D - Definitions as follows: 

recorded representation. – The printed, embossed, electronic, or other representation that is recorded 

as a quantity, unit price, total price, product identity or other information required by a weighing 

or measuring device. [1.10, 2.20, 2.21, 2.22, 2.24, 2.25, 3.30, 3.31, 3.32, 3.33, 3.34, 3.35, 3.36, 3.37, 

3.38, 3.39, 3.40, 5.54, 5.55, 5.56(a), 5.56(b), 5.57, 5.58, 5.60] 

recording element. – An element incorporated in a weighing or measuring device by means of which 

its the device’s performance relative to quantity or money value is permanently recorded electronically 

or on a tape, ticket, card, or the like, in the form of a printed, stamped, punched, or perforated 

representation or recorded electronically in instances where that option is permitted by specific 

code. [1.10, 2.20, 2.21, 2.22, 2.24, 2.25, 3.30, 3.31, 3.32, 3.33, 3.34, 3.35, 3.36, 3.37, 3.38, 3.39, 3.40, 

5.54, 5.55, 5.56(a), 5.56(b), 5.57, 5.58, 5.60] 

NIST OWM Detailed Technical Analysis:

Although NIST OWM feels that all proposed changes would benefit from additional review, NIST OWM 

believes that the additional changes made to G-S.5.6 provides clarity. NIST OWM believes a Developing 

status is appropriate so that changes to the B4 specific codes are carefully reviewed to ensure the proposed 

changes do not change the original intent of the specific section before moving these items forward for a 

vote. 

NIST OWM provided the previous comments. The key purpose of this block of proposals is to broaden 

the requirements by eliminating the term “print/printed” in specific NIST HB 44 codes and clarifying that 

providing an electronic recorded representation in lieu of a printed recorded representation is an acceptable 

option as was adopted in G-S.5.6. Recorded Representations in 2014. NIST OWM provides the following 

technical points for consideration.

Paragraph G-S.5.6. Recorded Representation addresses multiple points relative to recorded representations:

1. Any NIST Handbook 44 requirement applicable to indicating and recording elements also apply to 

recorded representations.
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2. Recorded values must be printed in a numerical or “digital” form. The reference to the term 

“digitally” refers to the use of that term as described in the definition for “digital type,” which 

describes “digitally” as being presented in numbers. 

3. Providing the customer with an option of “not receiving a receipt” is acceptable, so long as the 

customer is making that choice to not receive a receipt.

4. For systems that are capable of issuing an electronic receipt, the customer may be given the option 

of receiving the receipt in an electronic form. However, providing the option for an electronic 

receipt does not negate any requirement for the system to provide the customer with the option of 

a hard copy receipt for those specific codes where a hard copy receipt is required. That is, the 

system may offer additional options beyond the hard copy form; however, the hard copy form must 

remain an option for the customer to choose. The first part of this also sentence recognizes that not 

all systems are capable of providing an electronic option (though this would not preclude some 

codes from requiring such an option), but when such an option is available, the customer may 

choose that option over other options provided.

The current Item under Consideration presents the recommended changes to G-S.5.6. Recorded 

Representations as follows:

Current Item under Consideration in 2021 S&T Committee Interim Report:

G-S.5.6. Recorded Representations. – Insofar as they are appropriate, the requirements 

for indicating and recording elements shall also apply to recorded representations. All 

recorded values shall be printed provided presented digitally. In applications where 

recorded representations are required by a specific code, the customer may be given the 

option of not receiving the recorded representation. Unless otherwise specified, recorded 

representations referenced in specific codes shall be made available to the customer as 

a minimum in hard copy form. However, for systems equipped with the capability of 

issuing an electronic receipt, ticket, or other recorded representation, the customer may be 

given the option to receive any required information electronically (e.g., via cell phone, 

computer, etc.) in lieu of or in addition to a hard copy.

(Amended 1975, 2014 and 20XX)

With regard to the specific changes proposed to G-S.5.6., NIST OWM offers the following technical 

comments:

- Sentence 2: “All recorded values shall be printed provided presented digitally.”

OWM believes the proposed change to the second sentence in G-S.5.6. are appropriate. The 

original intent of the second sentence was to address the need for a numerical format. As noted 

above, the reference in that sentence to the term “digitally” refers to the use of that term as described 

in the definition for “digital type,” which describes “digitally” as being presented in numbers. The 

definition from NIST HB 44 Appendix D:

o digital type. – A system of indication or recording of the selector type or one that advances 

intermittently in which all values are presented digitally, or in numbers. In a digital 

indicating or recording element, or in digital representation, there are no graduations. [1.10]
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The word “printed” reflects the technology that was available at the time the requirements were 

written; the use of the word “printed” was not intended to limit recorded representations to only 

hard copy form. Thus, the use of the word “presented” in place of “printed” does not change the 

original intent of that statement and helps to recognize that other forms of recorded representations 

are now available.

As an editorial comment, OWM notes that the word “provided” is not part of the current language 

in G-S.5.6. Although the intent of showing the term as struck was to distinguish it from earlier 

versions of the proposal, this term should be struck from the proposal when presenting it for 

consideration.

- Sentence 3: “In applications where recorded representations are required by a specific code, the 

customer may be given the option of not receiving the recorded representation.”

OWM believes the proposed change to the third sentence by adding the term “by a specific code” 

is appropriate and simply emphasizes that individual codes may specify the need for a recorded 

representation.

- Sentence 4: “Unless otherwise specified, recorded representations referenced in specific codes 

shall be made available to the customer as a minimum in hard copy form.” 

OWM believes the addition of this new fourth sentence clarifies that the customer must have the 

option of receiving the recorded representation in hard copy form, but recognizes there may be 

some codes (such as the tentative code 3.40 for Electric Vehicle Fueling Systems) in which offering 

only an electronic form is acceptable.

- Sentence 5: “However, for systems equipped with the capability of issuing an electronic receipt, 

ticket, or other recorded representation, the customer may be given the option to receive any 

required information electronically (e.g., via cell phone, computer, etc.) in lieu of or in addition to 

a hard copy.”

OWM believes the addition of the word “However” is unnecessary and may cause confusion. The 

current form of the sentence is appropriate. Thus, OWM recommends striking the proposed 

addition of the word “However” at the start of that sentence.

Based on the assessment above OWM recommended the final proposal be modified to recommend the 

following:

G-S.5.6. Recorded Representations. – Insofar as they are appropriate, the requirements for 

indicating and recording elements shall also apply to recorded representations. All recorded values 

shall be printed presented digitally. In applications where recorded representations are required by a 

specific code, the customer may be given the option of not receiving the recorded representation. 

Unless otherwise specified, recorded representations referenced in specific codes shall be made 

available to the customer as a minimum in hard copy form. For systems equipped with the 

capability of issuing an electronic receipt, ticket, or other recorded representation, the customer may be 

given the option to receive any required information electronically (e.g., via cell phone, computer, etc.) 

in lieu of or in addition to a hard copy.

(Amended 1975, 2014 and 20XX) 
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These changes are represented in the 2022 Interim Meeting Report, Item under Consideration with the 

exception of striking “However” as recommended above. 

At the 2021 CWMA Annual Meeting, a suggestion was made to simplify G-S.5.6 by removing changes 

that were added to G-S.5.6 in 2014 to address systems with the capability of issuing an electronic receipt 

and, instead, specify the electronic receipt option as an acceptable form of receipt in each specific code. 

Although NIST OWM agrees that the General Code requirement may benefit from a restructuring of the 

paragraph to improve its use, NIST OWM believes there is value in providing information on options for 

recorded representation in the general code requirements. The specific intent of the decision made in 2014 

to include this language in the General Code was to avoid the need to add specific language to each code. 

By doing so, this avoids a situation in which a given code is inadvertently overlooked and the potential 

option for an electronic form of recorded representation may be in question. Thus, OWM does not believe 

the reference to electronic receipts should be removed from the General Code.

Nevertheless, if there is a desire to streamline the paragraph, the Submitter and the Committee may wish to 

consider using an alternate format such as sub-paragraphs or bulleted points to help clarify the various 

sections of the paragraph. For example, G-S.5.6. might be restructured as follows:

G-S.5.6. Recorded Representations. – The following shall apply to recorded representations.

(a) Insofar as they are appropriate, the requirements for indicating and recording elements shall 

also apply to recorded representations.

(b) All recorded values shall be printed presented digitally.

(c) In applications where recorded representations are required by a specific code, the customer 

may be given the option of not receiving the recorded representation.

(d) Unless otherwise specified, recorded representations referenced in specific codes shall be 

made available to the customer as a minimum in hard copy form. For systems equipped 

with the capability of issuing an electronic receipt, ticket, or other recorded representation, the 

customer may be given the option to receive any required information electronically (e.g., via 

cell phone, computer, etc.) in lieu of or in addition to a hard copy.

(Amended 1975, 2014 and 20XX) 

In addition to its comments regarding the proposed changes to paragraph G-S.5.6. Recorded 

Representations, NIST OWM also recommends the following editorial changes to this block of items:

B4: LMD-21.2 - UR.3.4. Printed Ticket. Strike out “Printed Ticket”

B4: VTM-21.1 - S.1.4.2. Printed Ticket Strike out “Printed Ticket”

These changes are represented in the 2022 Interim Meeting Report, Item under Consideration.

Summary of Discussions and Actions:

At the 2021 Interim Meeting Mr. Charles Stutesman (Kansas), submitter of the item, agreed that the item 

should be Developing and noted that updates to the Item under Consideration were provided to the S&T 

Committee based on reviews that he had with NIST OWM. Mr. Dmitri Karimov (MMA) commented that 
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the proposed changes to recognize electronically captured tickets are needed, editorial corrections are 

needed to some parts of the proposal, and he agreed with a developing status for this item. Ms. Diane Lee 

(NIST OWM) commented that there are two proposed changes to HB 44, Mass Flow Meter Code, 

Paragraph U.R.3.3 in the 2021 Interim Agenda. One proposal is Block 4 MFM-21.2 UR.3.3. (which was 

incorrectly number as UR.2.6 in the Item under Consideration in the 2021 Interim Meeting agenda) and the 

other is item MFM-21.1. UR.3.3. on the 2021 Interim Meeting agenda. The submitters should work 

together to provide one proposed change.

During the Committee work session, the Committee assigned a Developing status to Item Block 4.

At the 2021 Annual Meeting Mr. Charles Stutesman (Kansas) stated that he looks forward to maintaining 

developing status between now and the 2022 Interim. Mr. Stutesman explained that when the electronic 

receipt provision was added to NIST HB 44 General Code requirements, a change to the specific Codes 

were needed because the specific Codes supersede the General Code. All the code sections included in this 

block have printer requirements. As such, it was not the goal to remove printers but to add the option for 

electronic receipts if customer wants it. Mr. Stutesman would appreciate comments and suggestions for 

changes to the proposal. 

During the Committee work session, the Committee assigned a Developing status to Item Block 4. 

At the 2022 Interim Meeting Mr. Charles Stutesman (Kansas), submitter of the item noted that some editing 

and additional work is needed before forwarding as a Voting item. Mr. Stutesman recommended that the 

item remain Developing. California DMS recommended a Developing status for this item. Mr. Dmitri 

Karimov (MMA) commented that proposed changes to recognize electronically captured tickets are needed 

and that editorial corrections are needed to some parts of the proposal. Mr. Dmitri agreed with a developing 

status for this item. An SMA representative also commented on support for this item because it recognizes 

the importance of providing flexible options for recorded representations to customers. SMA sees value in 

the item and agreed with a Developing status for this item. NIST OWM agreed with the need to address 

current language in the proposal and supports development.

During the Committee work session, the Committee assigned a Developing status to Item Block 4. The 

Committee supports the work and recommends the continued work of all stakeholders. For more 

information or to provide comment, please contact:

Mr. Charles Stutesman

Kansas Department of Agriculture

(785) 564-6683, charles.stutesman@ks.gov

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Matt Douglas (California - DMS): California supports further development of the block. 

Mr. Russell Vires (SMA): SMA supports 2 of the items GEN-21.2, OTH-21.2. 
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Ms. Diane Lee (NIST OWM): carryover item. NIST has comments on this item posted. They support it 

as a Developing item going forward.

The WWMA S&T Committee recommends the status remain Developmental. The Committee recommends 

that the submitter continue to work with NIST OWM to further develop the item. 

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Russ Vires (SMA) stated that he supports this item. 

Mr. Tim Chesser (Arkansas) suggested changing the wording in Gen 21.1. His suggestion is to change 

“presented” to “available”. 

This Committee recommends this item remain Developing, so they have an opportunity to work with the 

NIST OWM to clarify and clean up the language.

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Jim Willis (New York) commented that it is important to recognize that the future will bring us to 

electronically captured tickets or receipts.

Mr. Lou Straub (SMA), John McGuire (New Jersey), and Jim Willis (New York) all recommended to move 

this item forward as Voting.

The NEWMA Specifications and Tolerances Committee recommends that this item be given Voting Status.

During the 2022 Annual Meeting Open Hearing Mr. Russ Vires (SMA) rose in support of GEN-21.2 and 

OTH-21.2. He commented that he supports the option for electronic receipts and tickets, and recognizes 

the need to provide options for consumers. No other comments were heard on this block.

After hearing comments from the floor, the committee recognized the need to further develop this block 

and recommended the block retain developing status.

Central Weights and Measures Association

During the 2021 Interim Meeting the Committee heard comments from the floor. Mr. Charles Stutesman

(Kansas) (submitter) mentioned that he hoped to have more information to NCWM Interim Meeting and 

supported this item staying as Developing. Ms. Diane Lee (NIST OWM) stated there are comments on this 

item in OWM’s Analysis that was sent to the Committee. Supports this item as Developing. Mr. Lou 

Straub (SMA) supports OTH-21.2.

CWMA S&T Committee recommends item as Developing.

During the 2022 Annual Meeting Open Hearing Mr. Charlie Stutesman (Kansas) stated that the item should 

remain as Developing. The item will be ready to present for status upgrade during the 2023 Interim Meeting 

or will be withdrawn.
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Mr. Russ Vires (SMA) - The SMA supports this item. The SMA recognizes the importance of providing 

flexible options for recorded representations to the consumer.

The CWMA S&T Committee recommends this item remain as Developing per the submitter’s request.

ITEM BLOCK 5 (B5) W DEFINE “FIELD REFERENCE STANDARD”

(Note: In 2019 this block of items was combined with Block 1 “Terminology For Testing Standards” and 

other items that addressed terminology for standards and the use of “master meters.” Based on comment 

heard during the 2021 Annual Meeting, the S&T Committee recommended that all items that were included 

in Block 1 “Terminology For Testing Standards” that originally appeared as a separate item or a separate 

block of items on the S&T agenda prior to 2019, be removed from Block 1 “Terminology For Testing 

Standards” and appear as originally presented. 

Item Block 5 “Define “Field Reference Standard”” was removed from Block 1 “Terminology For Testing 

Standards” and now appears as a separate block of items on the 2022 Interim Meeting agenda.) 

B5: CLM-18.2 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards

B5: CDL-18.2 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards

B5: HGM-18.2 W N.4.1. Master Meter (Transfer) Standard Test and T.4. Tolerance Application

on Test Using Transfer Standard Test Method

B5: OTH-18.3 W Appendix D – Definitions: field reference standard meter and transfer standard

Source: Endress + Hauser Flowtec AG USA (2018)

Purpose and Justification:

Add definition field reference standard meter to HB 44. Delete transfer standard definition. Change terms 

in sections 3.34, 3.38 and 3.39.

OWM Executive Summary for Item Block 5 (B5) Define “Field Reference Standard”

OWM Recommendation: No Recommendation. This item was withdrawn at the 2022 Interim 

Meeting. 

Table 3. Summary of Recommendations

V D W A I Notes* Comments 

Submitter 

 • Letter from Endress+Hauser requesting 

withdrawal of item (10-04-2021)

OWM 

WWMA 

SWMA 

NEWMA

5 • This item was not discussed because it was 

withdrawn at the 2022 NCWM Interim 

Meeting
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Table 3. Summary of Recommendations

V D W A I Notes* Comments 

CWMA 

5 • This item was not discussed because it was 

withdrawn at the 2022 NCWM Interim 

Meeting

NCWM 

Letters of Support Letters of Opposition Notes

Industry • Comments from 

Seraphin (09-22-2021)

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

 5 − No recommendation or not considered

Item under Consideration:

B5: CLM-18.2 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards

Amend Handbook 44, Cryogenic Liquid-Measuring Devices Code as follows:

N.3.2. Field Reference Transfer Standard Meter Test. – When comparing a meter with a calibrated 

field reference transfer standard meter, the test draft shall be equal to at least the amount delivered 

by the device in two minutes at its maximum discharge rate, and shall in no case be less than 180 L (50 

gal) or equivalent thereof. When testing uncompensated volumetric meters in a continuous recycle 

mode, appropriate corrections shall be applied if product conditions are abnormally affected by this test 

mode. 

(Amended 1976 and 20XX) 

T.3. On Tests Using Field ReferenceTransfer Standards Meters. – To the basic tolerance values 

that would otherwise be applied, there shall be added an amount equal to two times the standard 

deviation of the applicable field referencetransfer standard meter when compared to a basic reference 

standard. 

(Added 1976)

B5: CDL-18.2 W N.3.2. Transfer Standard Test and T.3. On Tests Using Transfer Standards

Amend Handbook 44, Carbon Dioxide Liquid-Measuring Devices Code as follows:

N.3.2. Field ReferenceTransfer Standard Meter Test. – When comparing a meter with a calibrated 

field referencetransfer standard meter, the test draft shall be equal to at least the amount delivered by 

the device in two minutes at its maximum discharge rate.
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(Amended 20XX)

T.3. On Tests Using Field ReferenceTransfer Standards Meters. – To the basic tolerance values 

that would otherwise be applied, there shall be added an amount equal to two times the standard 

deviation of the applicable field referencetransfer standard when compared to a basic field 

referencereference standard meter. 

(Amended 20XX)

B5: HGM-18.2 W N.4.1. Master Meter (Transfer) Standard Test and T.4. Tolerance Application 

on Test Using Transfer Standard Test Method

Amend Handbook 44, Hydrogen Gas-Measuring Devices Tentative Code as follows:

N.4.1. Field ReferenceMaster Meter (Transfer) Standard Meter Test. – When comparing a 

measuring system with a calibrated field referencetransfer standard meter, the minimum test shall be 

one test draft at the declared minimum measured quantity and one test draft at approximately ten times 

the minimum measured quantity or 1 kg, whichever is greater. More tests may be performed over the 

range of normal quantities dispensed.

(Amended 20XX)

T.4. Tolerance Application on Test Using Field ReferenceTransfer Standard Meters Test Method. – 

To the basic tolerance values that would otherwise be applied, there shall be added an amount equal to two 

times the standard deviation of the applicable field referencetransfer standard meter when compared to a 

basic reference standard.

B5: OTH-18.3 W Appendix D – Definitions: field reference standard meter and transfer 

standard

Amend Handbook 44, Appendix D as follows:

field reference standard meter – A measurement system designed for use in proving and testing 

measuring devices and meters.

transfer standard − A measurement system designed for use in proving and testing cryogenic 

liquid-measuring devices. 

NIST OWM Detailed Technical Analysis:

This item Block 5 was removed from Block 1 items of previous agendas and now appears as a separate 

item Block 5 on the 2022 Interim meeting agenda. NIST OWM provided previous comments in general to 

all items that were included in Block 1. These comments have been updated to address specific issues 

concerning this individual item.

The submitter of this item Mr. Michael Keilty recommended that this item be withdrawn. NIST OWM 

supports the withdraw of this item. This item was submitted when other definitions were submitted and 

being considered. There were those in opposition to the terms used in this proposal and introducing these 

new terms in the handbook. The Field task group assigned to developing items concerning the use of field 

standard meters to test meters in the field discussed these and other terms but did not decide on a term for 

use.
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Summary of Discussions and Actions:

At the 2022 Interim Meeting, Mr. Michael Keilty (the submitter of the items) provided written comments 

to the committee requesting that the block of items be withdrawn. Mr. Keilty also requested during the 

open hearing that these items be withdrawn. Ms. Diane Lee (NIST) agreed with the submitter and 

recommended that the items be withdrawn.

During the S&T Committee work session, the Committee agreed to recommend this item for withdrawal.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Michael Keilty (Endress + Hauser): he submitted these in 2017, sept. in response to NIST comments. 

NIST committed a form 15 in that same year with the language from Block 1. He had hoped that the task 

group formed in 2019 would have addressed block 1 and 5 items. Lang. in block 5 is in line with (LPG15.1 and MFM-15.1). Language in documents was copied and inserted. Asks Committee to look at 

language specific to the item and not the general block.

Mr. Kurt Floren (Los Angeles County, California): last reference was to block 5, error.

Mr. Keilty would like to move from Developing to a Voting status in the 2022 cycle.

Mr. Bob Murnane (Seraphin): new terminology that does not exist in HB currently. The definition 

proposed is vague. It does not limit the tolerance for field standard. W/M officials needs to know that 

enforcement is legally enforceable. HB 44 recognizes use of transfer standards and their uncertainty 

exceeds the 1/3. Several companies have proposed that mass flow meters be used. NIST is collecting data 

to evaluate Coriolis meter to possibly use as a field standard. It would be wrong to recognize Coriolis meter 

as a field standard (and that is what this is doing) without the proper tests. Doesn’t think we need new 

terminology. The existing terms (transfer standard / field standard) be worked on. Recommends that this 

item be withdrawn.

Mr. Josh Nelson (Ex-Officio NCWM S&T Committee): question: can he submit to the Committee his 

notes? He will. Recommend entire block be withdrawn?

Mr. Bob Murnane (Seraphin): yes (in reference to above testimony), withdraw entire block.

Mr. Keilty: to follow up on Mr. Murnane: these were not submitted to undermine the 1/3 tolerance. It is 

just assumed that the device will perform and the data will be provided. This is just enabling language.

The WWMA S&T Committee recommends the status remain Developmental. The Committee recommends 

that items MFM-15.1 and LPG-15.1 be inserted into Block 5 items as they refer to the same terminology in 

HB 44. A letter was submitted to the Committee by Mr. Bob Murnane (Seraphin) and will be posted to the 

NCWM website. 
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Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Keilty (Endress + Hauser), who is the submitter of this 

item, stated that he hoped the Field Standard Task Group would have worked on Blocks 1 and 5, but, 

unfortunately, that was not the case. He recommended this item be Withdrawn. Mr. Russ Vires (Mettler 

Toledo) recommended the Withdrawal of this item. Mr. Oppermann (Weights and Measures Consulting, 

Seraphin) supports Withdrawal of this item. 

This Committee recommends this item be Withdrawn at the submitters request. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Michael Keilty (Endress + Hauser Flowtec) has submitted comments and is requesting withdrawal of 

the items in this block.

Further comments were heard form Ms. Juana Williams (NIST OWM) on the history of the item. 

Comments were received in support of withdrawal.

The NEWMA Specifications and Tolerances Committee recommends Withdrawal of this item. 

During the 2022 Annual Meeting Open Hearing this item was not discussed because it was withdrawn at 

the 2022 NCWM Interim Meeting.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mr. 

Michael Keilty (Endress+Hauser Flow, submitter) recommends that item be Withdrawn. CWMA S&T 

Committee recommends that item be Withdrawn.

During the 2022 Annual Meeting Open Hearing this item was not discussed because it was withdrawn at 

the 2022 NCWM Interim Meeting.

ITEM BLOCK 6 (B6) D COMMERCIAL AND LAW ENFORCEMENT, AXLE AND AXLE 

GROUP WEIGHTS

B6: SCL-22.1 D S.1.14. Recorded Representation of Axle or Axle Group Weights

B6: SCL-22.3 D UR.3.3. Single-Draft Vehicle Weighing., and UR.3.4. Axle and Axle Group 

Weight Values.

Source: NIST Office of Weights and Measures

Purpose and Justification:

This proposed change is intended to add clarification regarding the implications of using weighing and 

measuring devices for transactions that may be considered by some as commercial while there is no clear 

guidance provided.
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OWM Executive Summary for Item Block 6 (B6) Commercial and Law Enforcement, 

Axle and Axle Group Weights

OWM Recommendation: The items in this block are in a Developing status. OWM is most interested 

at this time in receiving additional feedback from the community on each of these items in the block.

• When item SCL-22.1 of this block was originally proposed there was a lag in the publication process 

for 2020 and 2021; so the numbering of the paragraph in the Item under Consideration has been 

updated below to S.1.15.

• SCL-22.1 adds two new HB 44 Scales Code specification requirements to address how weight 

information generated from multi-independent platform vehicle scale systems is to be identified on 

a weigh ticket. 

• The first proposed sub-paragraph of SCL-22.1 (i.e., S.1.15.1) requires the ticket to clearly identify 

the particular independent scale platform associated with each printed weight value.

• The second proposed sub-paragraph of SCL-22.1 (i.e., S.1.15.2.) requires the summed total of all 

platforms to be identified as the vehicle’s total weight in instances where all axle and axle groups of 

the vehicle being weighed fit onto a live portion of the scale system and are weighed simultaneously 

as a single draft. In instances where the vehicle being weighed cannot be weighed as a single draft 

(e.g., oversized vehicles that do not fit onto the scale) thus necessitating weighing the vehicle in two 

drafts, the ticket must provide clear indication that the total weight is “not legal-for-trade” or similar 

text to make known the gross vehicle weight is not valid for use in commercial transactions.

• SCL-22.3 adds a new HB 44 Scales Code User Requirement to make clear the acceptable use of 

multi-platform vehicle scale systems to charge a fee for the commercial service of providing 

customers (usually truckers) axle weights, axle group weights, and total weight of their vehicles to 

enable them to determine compliance with state and federal legal load limits.

• Since the 2022 NCWM Interim Meeting, OWM has amended the proposal in SCL-22.3. and 

recommends it replace the current proposal for this item. An electronic copy of the revised proposal 

has been provided to the S&T Committee and has also been posted on NCWM’s website.

Table 3. Summary of Recommendations

Block 6 Items (B6) – Commercial and Law enforcement, Axle and Axle Group Weights

V D W A I Notes* Comments 

Submitter 

OWM

 

both 

SCL 

items

WWMA  1

SWMA 

NEWMA 

CWMA 
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Table 3. Summary of Recommendations

Block 6 Items (B6) – Commercial and Law enforcement, Axle and Axle Group Weights

V D W A I Notes* Comments 

NCWM

Letters of Support Letters of Opposition Notes

Industry

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

Item under Consideration:

B6: GEN-22.1 G.A.1. Commercial and Law-Enforcement Equipment. 

(NOTE: This item was removed from Block 6 and is now a standalone item. See the General Code Section 

in this report.) 

B6: SCL-22.1 Recorded Representation of Axle or Axle Group Weights

Amend NIST Handbook 44, Scales Code as follows:

S.1.15. Recorded Representations, Multi-Independent Platform1 Vehicle Scale Systems 

S.1.15.1. Axle and Axle Group Loads. - All recorded representations of the different axle and 

axle group loads of a vehicle weighed on a multi-independent platform vehicle scale system 

shall be identified by providing indication of either:

(a) the portion of the vehicle to which they represent (e.g., “axle-group 1, axle group 2, 

axle group 3,” or if using axle and axle group descriptions, “steering axle, drive axles, 

trailer axles”), or

(b) the particular independent scale platform from which they were obtained (e.g., 

“Platform 1, Platform 2, Platform 3”). 

S.1.15.2. Total Vehicle Weight. - If a summed total of all axle and axle group loads of a vehicle 

weighed on a multi-independent platformvehicle scale system is recorded, the recorded value 

shall be clearly identified as:
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(a) “Total Vehicle Weight,” “Vehicle Weight,” (or other similar terms that clearly 

identify the value as the vehicle’s total weight) providing all axle(s) and axle groups 

of the vehicle weighed were positioned on a live portion of the weighing/load-receiving 

elements and weighed simultaneously when the summed total was determined2, or 

(b) “Not-Legal-For-Trade” unless all axle and axle groups of the vehicle weighed were 

simultaneously positioned on a live portion of the weighing/load-receiving elements 

when the summed total was determined, or the vehicle was weighed using the 

alternative method described in footnote 2 of this paragraph. 

1 Multi-independent platform means each platform of the scale is a single independent 

weighing/load-receiving element unattached to adjacent elements and with its own A/D 

conversion circuitry and displayed weight.

2

Alternatively, the individual components of the vehicle being weighed may be uncoupled, 

positioned completely on the live elements of the scale, weighed separately, and then totaled. 

B6: SCL-22.3 D UR.3.3. Single-Draft Vehicle Weighing., and UR.3.4. Axle and Axle Group Weight 

Values.

Amend Handbook 44, Scales Code as follows: 

UR.3.3. Single-Draft Vehicle Weighing. – A vehicle or a coupled-vehicle combination shall be 

commercially weighed on a vehicle scale only as a single draft. That is, the total weight of such a 

vehicle or combination shall not be determined by adding together the results obtained by separately 

and not simultaneously weighing each end of such vehicle or individual elements of such coupled 

combination. However, the weight of:

(a) a coupled combination may be determined by uncoupling the various elements (tractor, 

semitrailer, trailer), weighing each unit separately as a single draft, and adding together the 

results; or

(b) a vehicle or coupled-vehicle combination may be determined by adding together the weights 

obtained while all individual elements are resting simultaneously on more than one scale 

platform. 

Note: This paragraph does not apply to highway-law-enforcement scales and scales used for the 

collection of statistical data.

(Added 1992)

And

UR.3.4. Axle and Axle Group Weight Values. – Weight values of axles or axle groups of highway 

motor vehicles are necessary to verify compliance with highway weight limit enforcement. When 

a fee is charged for the use of an axle-load scale or vehicle scale to determine the weight of axles 

or axle-groups, the transaction is considered to be “commercial” as defined by General Code 

paragraph G-A.1. Commercial and Law Enforcement Equipment and the scale shall comply with 

all applicable requirements for commercial weighing systems.
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When weight values for axles or axle groups are obtained using multiple-platform vehicle scales 

and where all parts of the motor vehicle are simultaneously resting on live elements of the scale, 

the weight values for axles or axle groups may be summed together to represent a commercial 

total gross weight of the motor vehicle. Weight values for axles or axle groups may also be 

summed to represent a commercial total gross weight of the motor vehicle if the individual 

components are uncoupled, positioned completely on the live elements, and weighed separately 

on the scale.

Weight values of axles or axle groups obtained from these weighing devices as individual weighing 

operations where all parts of the motor vehicle are not simultaneously resting on live portions of 

the scale shall not be used in commercial transactions and may only be used to verify compliance 

with highway weight limits.

(Renumber existing paragraphs UR.3.4 through UR.3.12.)

NIST OWM Detailed Technical Analysis:

OWM developed the two proposals in SCL-22.1 and SCL-22.3 to address perceived gaps in HB 44 Scales 

Code requirements pertaining to the design and use of multi-independent platform vehicle scale systems 

commercially used to charge a fee for the service of providing axle- and axle-group weights, as well as total 

vehicle weight to those needing them (typically commercial truck drivers). These systems are most often 

used commercially to verify compliance with federal and state vehicle load limits but at times may also be 

used to establish the net loads of products that are bought and sold by weight, establish transportation 

charges, and for other commercial purposes. 

These proposals were developed as the result of an OWM inquiry from a state questioning the permissible 

use of a multi-independent platform vehicle scale system (each platform having its own A/D conversion 

circuitry and weight indicator) that printed total vehicle weight from summing the axle- and axle-group 

loads of vehicles weighed when not all parts of those vehicles were able to fit onto a live portion of the 

scale and be weighed simultaneously. That is, the scale was being used on occasion to “split weigh” in two 

different drafts the different axle and axle groups of “over-sized” coupled-vehicle combinations because 

not all axle and axle groups would fit onto a live portion of the scale at the same time, which thus 

necessitated weighing those particular vehicles in multiple drafts. Even though the printed ticket for those 

weight determinations provided clear indication that the total vehicle weight value recorded was “non 

certifiable,” it is questionable whether or not a scale system is permitted to record this weight since HB 44 

Scales Code paragraph UR.3.3. Single-Draft Vehicle Weighing currently requires a vehicle or coupledvehicle combination to be commercially weighed on a vehicle scale only as a single draft. Note: The 

manufacturer of this particular scale system advised us that most vehicles and coupled-vehicle combinations 

that are weighed on the scale can be weighed as a single draft. That is, all axle and axle groups can be 

positioned onto a live portion of the scale to be weighed simultaneously. It is only the occasional oversized 

vehicle or coupled-vehicle combination that exceeds the length of the scale that must therefore be split 

weighed.

We purposely chose to simplify these proposals to only address multi-independent platform vehicle scale 

systems. These systems have been installed at truck stops (and perhaps other locations) throughout the US 

for many years and are used primarily to determine axle loads, axle-group loads, and total vehicle weight 

of vehicles and coupled-vehicle combinations for a fee. Although we recognize thatsingle-platform vehicle 

scales may also sometimes be used for this same purpose, we don’t view them as being suitable for the 

application. This is because the approach requirements for vehicle scales and axle-load scales in NIST 

HB44 are very different and few vehicle scales in commercial service have approaches that comply with 
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the approach requirements for axle-load scales. Axle-load scales are required to have a straight paved 

approach in the same plane as the platform on each end of the platform. The approaches must be the same 

width as the platform and of sufficient length to ensure the level positioning of vehicles during weight 

determinations. If vehicles aren’t level when the different axle and axle groups are weighed, a portion of 

the force of the load transfers to other axle and axle groups that aren’t positioned on the scale resulting in 

false indication. It is important to recognize that not all multi-independent platform vehicle scale systems 

may be installed with approach requirements meeting the HB 44 approach requirements for an axle-load 

scale. Many do, but we are unable to confirm that all do. We view this somewhat of an important concern 

given that these proposals, if adopted, would make it permissible to split weigh vehicles and coupledvehicle combinations for a fee providing the only use of the weighing results from doing so is to verify 

whether or not the different axle-, axle-group loads, and total vehicle weight are compliant with highway 

weight limits.

Another reason we elected to limit these proposals to only address multi-independent platform vehicle scale 

systems is that we do not believe it to be a very common practice to use single-platform vehicle scales to 

determine axle loads and axle-group loads of vehicles and coupled-vehicle combinations to verify 

compliance with federal and state vehicle load limits. Those that are using them for this purpose usually 

don’t charge a fee, i.e., the weighing is usually done as a complimentary service. 

NIST HB 44 does not currently require a multi-independent platform vehicle scale system to be equipped 

with a ticket printer and whether or not one should be required, is something to be considered. We have 

not proposed it, but perhaps others will conclude this would be an important HB 44 addition. We believe 

most (perhaps all) of the multi-independent platform vehicle scale systems currently in commercial service 

have been equipped with a ticket printer and this is likely because the few scale manufacturers of these 

systems recognize the need for the multiple indications displayed by these systems to be made available in 

printed form to the operator and customer. We also believe most of the systems currently in service comply 

with both newly proposed sub-paragraphs of S.1.14. We developed these two new sub-paragraphs 

(S.1.14.1. and S.1.14.2.) because it is important for scale operators, customers, and enforcement officials 

to be able to clearly identify from a weigh ticket the different scale platforms utilized at the time a vehicle 

was weighed and their corresponding scale indications so that the accuracy of those values (including the 

summed total) can be verified. It is also important to clearly specify on a weigh ticket generated from one 

of these scale systems that any recorded total vehicle weight value determined from summing the different 

axle- and axle-group loads of a vehicle or coupled-vehicle combination weighed in multiple drafts (i.e., 

split weighed) is “Not-Legal-For-Trade.” 

Paragraph UR.3.3. needs to be amended to address the current use of multi-independent vehicle scale 

systems to split weigh oversized vehicles for a fee. The current paragraph does not take into consideration 

both the past and present use of these scales to provide a total vehicle weight that’s most often only used to 

verify compliance with maximum legal load limits and safe distribution of the load. These systems have 

been in existence at truck stops for many years and their primary commercial use is to provide axle weights, 

axle group weights, and total vehicle weight to commercial haulers for a fee so that those haulers are able 

to determine whether or not their loads are distributed safely and within legal load limits. Years ago, (prior 

to the existence of multi-independent platform vehicle scale systems) axle-load scales served this same 

purpose at truck stops throughout the US and summing of the different axle and axle groups to determine 

total vehicle weight was undoubtedly done to ensure total vehicle weight didn’t exceed maximum legal 

load limits when using those scales. It is also important to recognize that the weight values corresponding 

to the different axle- and axle-group loads of vehicles weighed on a multi-independent platform vehicle 

scale system are not constant; but rather fluctuate/change depending on the position of those axles and axle 

groups on the different platforms of the system when the vehicle is weighed. That is, a change of the scale 

indication of one platform is offset by a change in the opposite direction of the indication from one or both 
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of the other platforms if the position of a vehicle being weighed is changed slightly forward or backwards 

from its initial position. It is only the summed total of all indications that is constant; although it too changes 

minimally since not all sections of all platforms are typically adjusted the same. For these reasons, OWM 

has provided the Committee an updated proposal to amend Scales Code paragraph UR.3.3., which would 

make it permissible to weigh in multiple drafts (i.e., split weigh) a vehicle or coupled-vehicle combination 

and charge a fee for the service of providing weights of the different axle- and axle-group loads when the 

only use of those values is to determine compliance with highway legal load limits. 

Summary of Discussions and Actions:

Mr. Rick Harshman (NIST OWM) provided the Committee a high-level summary of its analysis of the two 

remaining items in Block 6, which included much of background information that had led OWM to submit 

the two proposals in Block 6 as well as the GEN-22.1 G.A.1. Commercial and Law-Enforcement Equipment 

item, which the Committee had previously removed from Block 6. Mr. Harshman reported that OWM had 

recently provided the Committee an updated version of the proposal in SCL-22.1 and requested the 

Committee replace the version of SCL-22.1 in its current agenda with the updated version recently received. 

Mr. Harshman also reported that OWM planned to revise the proposal in SCL-22.3 and would later 

(sometime following the 2022 NCWM Interim Meeting) submit the revised version to the Committee in 

hopes it could be reviewed by one or more of the regional weights and measures associations meeting in 

the Spring and/or Fall of 2022. Mr. Harshman recommended both items remain in a developing status to 

allow stakeholders time to review and recommend any changes they felt necessary.

Mr. Russ Vires (Mettler Toledo LLC) speaking on behalf of the SMA reported that the SMA recommends 

Block 6 be broken apart into three individual items (i.e., GEN-22.1 Commercial and Law-Enforcement 

Equipment, SCL-22.1 Recorded Representation of Axle or Axle Group Weights, and SCL-22.3 UR.3.3. 

Single-Draft Vehicle Weighing and UR.3.4. Axle and Axle Group Weight Values). Mr. Vires then 

provided the SMA’s position and rationale for each of these items speaking verbatim from the SMA’s 

November 2, 2021 report titled “SMA Positions on the NCWM Specification and Tolerances Committee 

Report (For the NCWM Interim Meeting, January 2022, Developed November 2, 2021). NIST Technical 

Advisors note: Refer to the subheading shown below titled, “Scale Manufacturers Association (SMA-Fall 

2021 Meeting)” to view the different positions and rationales provided by Mr. Vires on behalf of the SMA 

for the items in Block 6. Mr. Vires also reported that the SMA had had the opportunity during its Fall 2021 

meeting to review the updated version of the proposal in SCL-22.1 that OWM had provided the Committee 

for replacement of the one in its current agenda and that the SMA supported the changes OWM had made.

These were several officials who spoke in support of further development of the two items in Block 6. 

Mr. Lou Straub (Fairbanks Scale) reported that Fairbanks Scale had been manufacturing the multi-platform 

“CAT” vehicle scale system for over forty years and the systems had been installed in approximately 2,000 

locations. He also reported that he fully supported the GEN-22.1 item that the Committee had earlier 

removed from Block 6. Referencing the proposal in SCL-22.1, Mr. Straub stated he agreed that the recorded 

representation of weights from individual axle or axle groups need to be clearly identified as 

“not-legal-for- trade” on the printed ticket unless the entire vehicle is positioned on live elements of the 

vehicle scale system and all axles/axle groups are weighed simultaneously. He voiced disagreement with 

the second sentence proposed in paragraph S.1.14. noting that when one considers a truck with six to eight 

axle groups that cannot fit onto the different independent platform and be weighed simultaneously, 

identifying which platform weighed each of these axle and axle groups becomes unnecessary. 
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The Committee, in consideration of the comments received during open hearings, agreed to replace the 

Block 6 SCL-22.1 proposal in its Interim Meeting agenda (2022 NCWM Publication 15) with the updated 

version provided by OWM just prior to the 2022 NCWM Interim Meeting and maintain a developing status 

on the two remaining items in Block 6. The following proposal represents the Block 6 SCL-22.1 item 

appearing in the 2022 version of NCWM Publication 15 that the Committee agreed to replace with the Item 

under Consideration now shown in SCL-22.1:

Item under Consideration:

Amend Handbook 44, Scales Code as follows: 

S.1.14. Recorded Representation of Axle or Axle Group Weights. – The recorded 

representation of weights from individual axle or axle group weights shall clearly be identified as 

“not legal for trade” or “non-commercial” weight values unless the entire vehicle is positioned on 

live elements of a multiple-platform vehicle scale and where all axles/axle groups are weighed 

simultaneously. All recorded weights of axles/axle groups shall be identified as representing only 

a portion of the vehicle’s total gross weight (e.g., by axle groupings such as: “axle group 1,” “axle 

group 2,” “axle group 3,” or by individual axle description such as: “steering axle,” “drive axles,” 

“trailer axles”).

Any total gross weight of the vehicle included in the recorded representations determined by 

summing axle weights shall be clearly identified as “not-legal-for trade” or “non-commercial” 

unless those axle weights were recorded when all parts of the vehicle rested simultaneously on 

live portions of the scale, or the individual components were uncoupled, positioned completely on 

the live elements, and weighed separately on the scale.

[subsequent requirements to be renumbered as appropriate]

On May 19, 2022, OWM provided S&T Committee Chair Mr. Bradford Bachelder an electronic file 

containing the following revised version of the B6: SCL-22.3 proposal as replacement for the current 

proposal in 2022 NCWM Publication 16. OWM requested he share it with the Committee to be considered 

as replacement for the current proposal in the Committee’s agenda.

OWM’s Revised Replacement Proposal for B6: SCL-22.3 UR.3.3. Single-Draft Vehicle 

Weighing, and UR.3.4. Axle and Axle Group Weight Values.

Amend NIST Handbook 44, Scales Code as follows:

UR.3.3. Single-Draft Vehicle Weighing. – A vehicle or a coupled-vehicle combination shall be 

commercially weighed on a vehicle scale only as a single draft. That is, the total weight of such a 

vehicle or combination shall not be determined by adding together the results obtained by separately 

and not simultaneously weighing each end of such vehicle or individual elements of such coupled 

combination. However, the weight of:

(a) a coupled combination may be determined by uncoupling the various elements (tractor, 

semitrailer, trailer), weighing each unit separately as a single draft, and adding together the 

results; or
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(b) a vehicle or coupled-vehicle combination may be determined by adding together the weights 

obtained while all individual elements are resting simultaneously on more than one scale 

platform.

Note: This paragraph does not apply to highway-law-enforcement scales, and scales used for the 

collection of statistical data, or scales used to charge a fee for the service of providing weights of 

the different axle-, axle-group loads, and total weight of vehicles and coupled-vehicle 

combinations when the only use of those values is to determine compliance with highway legal 

load limits and safe distribution of the load. 

(Added 1992)

UR.3.4. Weighing of Axle- and Axle-Group Loads – Establishing weight values for the different 

individual axle- and axle-group loads of a vehicle or coupled-vehicle combination is oftentimes 

necessary to verify compliance with state and federal highway load limits. When a fee is charged 

for the use of an axle-load scale or vehicle scale to determine such values, the transaction is 

considered “commercial” under the provisions of the General Code paragraph G-A.1. 

Commercial and Law Enforcement Equipment and the scale shall comply with all applicable 

NIST Handbook 44 requirements for commercial weighing systems. 

When weight values for axle- and/or axle-group loads are obtained using multiple-independent 

platform vehicle scales systems where all parts of the vehicle or coupled-vehicle combination 

being weighed are simultaneously positioned on live elements of the scale, the values for the 

different axle- and axle-group loads may be summed to establish the commercial gross weight. 

In no case, however, shall a summed result of the different axle- and axle-group loads of a vehicle 

or coupled vehicle combination weighed in multiple drafts be used for commercial purposes 

except as provided in subparts (a) and (b) of paragraph UR.3.3. Single-Draft Vehicle Weighing

Renumber existing paragraphs UR.3.4 through UR.3.12.

Regional Association Reporting:

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Kurt Floren (Los Angeles County, California): he wants to offer that the last part of subsection A and 

breaking into bullet points. He wants to break out equipment that is commercial, then the other types. It's 

titled commercial and law enforcement then "other commercial" and it becomes confusing. Is it all 

commercial and subsect to our jurisdiction? rephrase GA-1 : apply "to commercial equipment as follows": 

... explains that everything under is commercial. (strike "commercial" from A and B). Between apply and 

as in the first line, insert commercial equipment. Mr. Kurt Floren stated that he will submit a written 

statement to the Committee as presented during open hearings. 

Mr. Ivan Hankins (Iowa): he wants clarification as to what is being changed to make it better. It looks like 

it's already there, and he wants more definition on why this is changing.

Ms. Cadence Matijevich (Nevada): agreed with Mr. Floren, but cautions that we consider how the heading 

reads if we add commercial to the opening statement then there might be some interpretation that what is 
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or is not commercial law enforcement equipment. (Is there a fine assessed?) does not want to narrow the 

subsection of law enforcement devices only to commercial purposes.

Mr. Kurt Floren (Los Angeles County, California): fix to Ms. Matijevich: restructure under GA-1: insert 

subsection under 1: commercial as follows, then insert A,B,C then 2 for law enforcement.

Ms. Cadence Matijevich (Nevada) - stated that Mr. Floren is much better at this, and his fix is good.

Mr. Lou Straub (Fairbanks Scales): agreed with Mr. Hankins, that the original language is satisfactory. 

Language needs to say that its NTEP approved and meet handbook requirements.

Mr. Eric Golden (Cardinal Scale): does a commercial transaction include just getting a weight: he says 

yes. Change the wording that that transaction is commercial. No suggestions at this time. Mr. Floren

missed a typo: in B2: “Basis”. 

Mrs. Tina Butcher (NIST OWM): their office submitted this. Wanted to clarify commercial transactions. 

Agreed with previous testimony. They have submitted other proposals to amend method of sale reg. and 

uniform law. They have determined that HB 44 and 2 sections in HB 130 are slightly different. Uniform 

Reg. for service persons also needs to be aligned. Wants this to remain Developing so that they can continue 

to align the language and make it more uniform.

Mr. Russell Vires (Scale Manufactures Association): This is a new item, the SMA has not vetted this yet. 

They will do so at November meeting. This should remain Developing so that there’s no unintended 

consequences.

Mrs. Tina Butcher (NIST OWM): In the agenda, this is blocked with two other "companions". She feels 

that the block should continue, however, if others think that other items in the block are ready (SCL-22.1 

and SCL-22.3) those items can move forward.

Mr. Don Onwiler (NCWM): SCL-22.3 is the name of the next item. 

Mr. Russell Vires (Scale Manufactures Association): he is looking at it as a block and is commenting as 

an entire block. Wants all 3 to remain Developing so that they can research.

Mr. Lou Straub (Fairbank Scales): SCL-22.1: concern about the second sentence: talking about the entire 

truck on the scale = not legal for trade: this is ok. Second part about axle identifications (axle groups) this 

gets difficult to identify group notifications. Wants the ticket that has already been marked as not legal for 

trade to not have to identify all axels. Wants this re-worded. They will put down axle weight and gross 

weight. Preprinted labels don't allow enough space.

Mr. Eric Golden (Cardinal Scales): agreed with Mrs. Butcher to split the items. “Blow the block apart.” 

The second two items introduce additional items and topics. Wants to pull the second two items out.

The WWMA S&T Committee recommends that this be assigned a Developmental status. The Committee 

recommends following the submitter’s request to remove GEN-22.1 from the Block. Based on testimony 

heard the Committee agreed to submit the following language for item GEN-22.1. The Committee notes 

that SCL-22.1 (UR.3.3.) item was reassigned as SCL-22.3. 

G-A.1. Commercial and Law-Enforcement Equipment. – These specifications, tolerances, and

other technical requirements apply as follows:
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(1) To commercial weighing and measuring equipment

(a) To commercial weighing and measuring equipment; that is, tTo weights and measures and 

weighing and measuring devices commercially used or employed in establishing the size, 

quantity, extent, area, composition (limited to meat and poultry), constituent values (limited to 

grain), or measurement of quantities, things, produce, or articles for distribution or 

consumption, purchased, offered, or submitted for sale., hire, or award, or in computing any 

basic charge or payment for services rendered on the basis of weight or measure.

(Amended 2008 and 20XX) 

(d) To other commercial weighing and measuring equipment:

i. when there is a fee assessed for the use of the equipment to determine a weight or 

measure;

ii. used to determine the bases of an award using count, weight, or measure; or

iii. used in computing any basic charge or payment for services rendered on the basis of 

weight or measure

(Added 20XX)

(bc)To any accessory attached to or used in connection with a commercial weighing or measuring 

device when such accessory is so designed that its operation affects the accuracy of the device. 

(cd)(2) To weighing and measuring equipment in official use for the enforcement of law or for the 

collection of statistical information by government agencies.

(These requirements should be used as a guide by the weights and measures official when, upon request, 

courtesy examinations of noncommercial equipment are made.)

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Russ Vires (Mettler Toledo) stated that this item needs 

work on the wording and further review by stakeholders. Its current language could have unintended 

consequences, and recommended it continue with a Developing Status. 

This Committee would like clarification on the purpose and use of axle weight scale values allowed by this 

proposal beyond law enforcement use. 

This Committee recommends that this item move forward with a Developing status. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

GEN-22.1 

Mr. Rick Harshman (NIST OWM) commented that the language is in-need of some changes and NIST will 

be providing changes for the NCWM.
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Mr. Eric Golden (Cardinal Scale) supports the intent of this item, but it may need some wordsmithing.

Mr. Lou Straub (SMA), Cheryl Ayer (New Hampshire), and John McGuire (New Jersey) all support this 

as a Developing item.

SCL 22.1

Mr. Eric Golden (Cardinal Scale) supports this item moving forward as Developing.

Mr. Lou Straub (Fairbanks Scale) agreed with language in general. But questions the benefit of including 

all the language on a scale ticket and the large amount of information would be difficult to fit on the ticket.

Mr. Eric Golden (Cardinal Scale) and Ms. Cheryl Ayer (New Hampshire) agreed with comments from Mr. 

Straub. 

Mr. John McGuire (New Jersey) recommended keeping this item in Developing status.

SCL 22.3

Mr. Eric Golden (Cardinal Scale) suggested to strike “non-commercial” and additional wordsmithing to 

align with paragraph UR3.4.

Mr. John McGuire (New Jersey) supports keeping this item in Developing status.

The NEWMA Specifications and Tolerances Committee recommends that this item be given a Developing 

Status.

During NEWMA’s 2022 Annual Meeting Open Hearings, the Committee heard the following comments: 

Mr. Russ Vires (SMA) recommends Block 6 be broken into two separate items. Mr. Vires indicated his 

supports this item with the following language change: S.1.14.1. Axle and Axle Group Loads. - All recorded 

representations of the different axle and axle group loads of a vehicle when weighed in a single draft on a 

multi-independent platform vehicle scale system shall be identified by providing indication of either. Mrs. 

Tina Butcher (NIST OWM) commented that this item needs development. 

After hearing comments from the floor, the Committee recognized the need to further develop this block 

and recommended the block retain Developing status. 

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mr. Loren 

Minnich (Kansas) suggested change he sent to the Committee (in green).

B6: GEN-22.1 G-A.1. Commercial and Law-Enforcement Equipment. – These specifications, 

tolerances, and other technical requirements apply as follows:

(a) To commercial weighing and measuring equipment; that is, to weights and measures and 

weighing and measuring devices commercially used or employed in establishing the size, 

quantity, extent, area, composition (limited to meat and poultry), constituent values (limited to 

grain), or measurement of quantities, things, produce, or articles for distribution or 
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consumption, purchased, offered, or submitted for sale., hire, or award, or in computing any 

basic charge or payment for services rendered on the basis of weight or measure.

(Amended 2008 and 20XX) 

(d) To other commercial weighing and measuring equipment:

i. when there is a fee assessed for the use of the equipment to determine a weight or 

measure;

ii. used to determine the bases of an award using count, weight, or measure when using 

weight, measure, or count as the basis to determine an award; or

iii. used in computing any basic charge or payment for services rendered on the basis of 

weight or measure

(Added 20XX)

Mr. Loren Minnich (Kansas) also asked NIST for clarification on G-A.1. because different states already 

interrupt rule different ways. Ms. Diane Lee (NIST OWM) agreed with Mr. Minnich and suggested it be 

Developing. Mr. Eric Golden (Cardinal Scales) agreed with the spirit of the proposal; it is indeed a 

“commercial transaction” to charge a person a fee solely for the purpose of obtaining a weight of a vehicle 

– it is not required to have to undergo a sales transaction of weighed product in order for it to be considered 

a commercial transaction. Mr. Golden also recommended striking out the following (in red) stating the 

reasoning behind this is by leaving the “non-commercial” language in the proposal, it defeats the purpose 

of the proposal, which is to officially clarify what a non-commercial transaction is.

B6: SCL-22.1 S.1.14. Recorded Representation of Axle or Axle Group Weights

S.1.14. Recorded Representation of Axle or Axle Group Weights. – The recorded representation 

of weights from individual axle or axle group weights shall clearly be identified as “not legal for 

trade” or “non-commercial” weight values unless the entire vehicle is positioned on live elements 

of a multiple-platform vehicle scale and where all axles/axle groups are weighed 

simultaneously. All recorded weights of axles/axle groups shall be identified as representing only 

a portion of the vehicle’s total gross weight (e.g., by axle groupings such as: “axle group 1,” “axle 

group 2,” “axle group 3,” or by individual axle description such as: “steering axle,” “drive axles,” 

“trailer axles”).

Any total gross weight of the vehicle included in the recorded representations determined by 

summing axle weights shall be clearly identified as “not-legal-for trade” or “non-commercial”

unless those axle weights were recorded when all parts of the vehicle rested simultaneously on 

live portions of the scale, or the individual components were uncoupled, positioned completely on 

the live elements, and weighed separately on the scale.

Mrs. Tina Butcher (NIST OWM) agreed G-A.1. needed more work and had no objection to Mr. Golden’s 

suggestion of splitting SCL-22.1 and SCL-22.3. Mr. Lou Straub (Fairbanks) says current G-A.1. is already 

correct. He also agreed with Mr. Golden from Cardinal Scales on SCL 22.1. Mr. Doug Musick (Kansas) 

agreed with Mr. Straub. Says that item is not practical for all vehicles out there. Keep as Developing. Mr. 

Ivan Hankins (Iowa) feels G-A.1. is already correct. Mr. Charles Stutesman (Kansas) stated original 

language is good as written.
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CWMA S&T Committee recommends that GEN 22.1 be withdrawn and SCL-22.1 and SCL 22.3 remain 

Developing.

During the 2022 CWMA Annual Meeting Open Hearing the Committee heard the following comments: 

Mr. Russ Vires (SMA) - The SMA recommends that Block 6 be broken apart into two (2) individual items. 

Each of these items deals with a separate topic that needs to be discussed individually. Regarding SCL22.1: The SMA supports this item with the following changes: “S.1.14.1. Axle and Axle Group Loads. - 

All recorded representations of the different axle and axle group loads of a vehicle when weighed in a 

single draft on a multi-independent platform vehicle scale system shall be identified by providing 

indication of either:” 

Identifying the recorded weight values for the axle/axle groups as required in S.1.14.1.(a) is only necessary 

when the vehicle can be weighed in a single draft.

The CWMA agreed to recommend further development of this block of items.

Scale Manufacturers Association (SMA-Fall 2021 Meeting)

The SMA recommends that Block 6 be broken apart into three (3) individual items. 

Rationale: Each of these items deals with a separate topic that needs to be discussed individually.

B6: GEN-22.1 G.A.1. COMMERCIAL AND LAW-ENFORCEMENT EQUIPMENT

Position: The SMA supports this item.

Rationale: The proposed item provides clarity to define what constitutes a “commercial transaction”.

B6: SCL-22.1 S.1.14. RECORDED REPRESENTATION OF AXLE OR AXLE GROUP WEIGHTS

Position: The SMA supports this item with the following changes:

S.1.14. Recorded Representation of Axle or Axle Group Weights. – The recorded representation of 

weights from individual axle or axle group weights shall clearly be identified as “not legal for trade” 

or “non-commercial” weight values unless the entire vehicle is positioned on live elements of a 

multiple-platform vehicle scale and where all axles/axle groups are weighed simultaneously. All 

recorded weights of axles/axle groups shall be identified as representing only a portion of the vehicle’s 

total gross weight (e.g., by axle groupings such as: “axle group 1,” “axle group 2,” “axle group 3,” or

by individual axle description such as: “steering axle,” “drive axles,” “trailer axles”).

Any total gross weight of the vehicle included in the recorded representations determined by 

summing axle weights shall be clearly identified as “not-legal-for trade” or “non-commercial” unless

those axle weights were recorded when all parts of the vehicle rested simultaneously on live portions

of the scale, or the individual components were uncoupled, positioned completely on the live 

elements, and weighed separately on the scale.

Rationale: The item attempts to define what constitutes a “commercial transaction”, but the words “noncommercial” reduces its clarity. Secondly, it is not necessary to label each weight value of axle/axle group 
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weights as “not legal for trade”; putting the words “not legal for trade” on the recorded representation once 

is adequate.

B6: SCL-22.3 UR.3.3. SINGLE-DRAFT VEHICLE WEIGHING., AND UR.3.4. AXLE AND AXLE 

GROUP WEIGHT VALUES

Position: The SMA supports this item.

SMA-Spring 2022 Meeting 

The SMA recommends that Block 6 be broken apart into three (3) individual items.

Rationale: Each of these items deals with a separate topic that needs to be discussed individually.

B6: SCL-22.1 D S.1.14. RECORDED REPRESENTATION OF AXLE OR AXLE GROUP WEIGHTS

Position: The SMA supports this item with the following changes:

S.1.14.1. Axle and Axle Group Loads. All recorded representations of the different axle and

axle group loads of a vehicle when weighed in a single draft on a multi-independent platform vehicle 

scale system shall be identified by providing indication of either:

Rationale: identifying the recorded weight values for the axle/axle groups as required in S.1.14.1.(a) is

only necessary when the vehicle can be weighed in a single draft.

B6: SCL-22.3 D UR.3.3. SINGLE-DRAFT VEHICLE WEIGHING., AND UR.3.4.

AXLE AND AXLE GROUP WEIGHT VALUES

Position: The SMA supports the intent of this item and believes that additional work is necessary.

ITEM BLOCK 7 (B7) D TOLERANCES ON TESTS USING TRANSFER STANDARDS

Note: The Item under Consideration was revised by the submitter based on comments from the 2022 Interim 

Meeting. 

Source: Seraphin Test Measure Company, A Division of Pemberton Fabricators, Inc.

Purpose and Justification:

The purpose of these proposals is to change the language in the tolerance paragraphs to provide consistency 

with the changes in the combined amended proposals of 2022 S&T Agenda Item Block 8 (GEN-19.1. and 

OTH-22.1). In the codes mentioned below, the current language of Handbook 44 states that when transfer 

standards are used, the basic tolerances to be applied to the devices under test are to be increased by the 

uncertainty of the transfer standard (i.e., two times the standard deviation of the transfer standard). The 

proposed language simply states that the formula given in the General Code (the proposed G-T.5.) be used, 

rather than repeat the formula in each of the specific codes listed below.
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OWM Executive Summary for Item Block 7 (B7) – Tolerances on Tests Using Transfer 

Standards

OWM Recommendation: When the S&T Committee presents Block 8 for a vote, OWM agrees that 

Block 7 should also go forward for a vote.

• Block 7 Items are proposed changes to NIST HB 44 Codes that have transfer standard tolerance 

requirements.

• Because of the larger uncertainties associate with the use of transfer standards, the current Code 

requirement increases the tolerance to account for the uncertainties in the tolerance.

• The proposal is to revise the transfer standard tolerance requirements with an equation to calculate 

the tolerances for Type 2 Transfer standards and to clarify that these standards are considered Type 

2 standards. 

• The equation places an upper limit on how large the uncertainty associated with the transfer standard 

can be.

Table 3. Summary of Recommendations

Block 7 Items (B7) Tolerances on Tests Using Transfer Standards

V D W A I Notes* Comments

Submitter 

• Updated Proposal from Seraphin Test 

Measure Co requesting Block 7 be 

designated as a Voting item when Block 

8 is designated as Voting.

• (01-06-2022)

OWM  • When Block 8 is voting

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes

Industry

Comments from 

Emerson-Micro Motion 

(09-27-21)

Manufacturers

Retailers and Consumers
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Table 3. Summary of Recommendations

Block 7 Items (B7) Tolerances on Tests Using Transfer Standards

V D W A I Notes* Comments

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

B7: CLM-22.1 D T.3. On Tests Using Type 2 Transfer Standards.

Amend Handbook 44, Cryogenic Liquid-Measuring Devices Code as follows:

T.3. On Tests Using Type 2 Transfer Standards. – To the basic tolerance values that would otherwise 

be applied, there shall be added an amount equal to two times the standard deviation of the applicable 

transfer standard when compared to a basic reference standard. When commercial meters are tested 

using a Type 2 transfer standard, the tolerance applied to the meter under test shall be calculated 

using the formula specified in the General Code Tolerance section. 

(Amended 202X)

B7: CDL-22.1 D T.3. On Tests Using Type 2 Transfer Standards.

Amend Handbook 44, Carbon Dioxide Liquid-Measuring Devices Code as follows:

T.3. On Tests Using Type 2 Transfer Standards. – To the basic tolerance values that would otherwise 

be applied, there shall be added an amount equal to two times the standard deviation of the applicable 

transfer standard when compared to a basic reference standard. When commercial meters are tested 

using a Type 2 transfer standard, the tolerance applied to the meter under test shall be calculated 

using the formula specified in the General Code Tolerance section.

(Amended 202X)

B7: HGM-22.1 D T.4. Tolerance Application on Tests Using Type 2 Transfer Standard Test 

Method.

Amend Handbook 44, Hydrogen Gas-Measuring Devices Code as follows:

T.4. Tolerance Application on Tests Using Type 2 Transfer Standard Test Method. – To the basic 

tolerance values that would otherwise be applied, there shall be added an amount equal to two times 

the standard deviation of the applicable transfer standard when compared to a basic reference standard. 

When commercial meters are tested using a Type 2 transfer standard, the tolerance applied to 

the meter under test shall be calculated using the formula specified in the General Code 

Tolerance section.

(Amended 202X)
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NIST OWM Detailed Technical Analysis:

Seraphin proposed Block 7 Items to address the changes that are proposed in Block 8 concerning transfer 

standards. Block 7 items in the Interim Meeting Report were revised based on comments heard during the 

2022 Interim Meeting.

Transfer standards are address in the Cryogenic Liquid-Measuring Devices Code, the Carbon Dioxide 

Liquid-Measuring Devices Code and the Hydrogen Gas-Measuring Devices Code. These codes already 

specify that a larger tolerance be used when transfer standards are used to account for the higher uncertainty 

associated with these types of standards and the fact that they will not likely meet the fundamental 

considerations paragraph 3.2 tolerances for Standards. 

The proposed changes in Block 8 define the different types of standards (Field Standard, Type 1 Transfer 

Standard and Type 2 Transfer Standard). Block 8 also proposes to add a General code requirement with an 

equation that should be used to determine the tolerance for type 2 transfer standards because Type 2 transfer 

standards will not likely meet the fundamental considerations concerning the error and uncertainty. The 

equation places an upper limit on how large the uncertainty associated with the transfer standard can be.

Block 7 makes changes to the aforementioned codes to reference the General Code requirement with the 

equation that will be used to calculate the tolerance when using type 2 transfer standards in these codes. 

When the S&T Committee presents the combined item GEN-19.1 and OTH-22.1, Block 8 item for a vote, 

then this item, Block 7 may also go forward for a vote.

Summary of Discussions and Actions:

At the 2022 Interim Meeting the Committee recommended that this item be given a Developing status for 

further development by the submitter based on comments heard during the 2022 Interim Meeting. Since 

the 2022 Interim Meeting, the submitter made additional changes to the items under consideration which 

are currently reflected in Block 7 above. These changes add “Type 2” to clarify the type of transfer standard 

and references the revised equation in the proposed Block 8 item of this report. 

Regional Association Reporting: 

Western Weights and Measures Association

During the 2021 Annual Meeting Open Hearings the following comments were heard:

Mr. Bob Murnane (Seraphin): submitter: this needs to go with the GEN-19.

Mr. Marc Buttler (Emerson Micro Motion): wants to re-state: earlier comment on GEN item would also 

apply to calculation on this. He will adjust the calculation to increasing tolerance from decreasing.

Mr. Bob Murnane (Seraphin): they have looked at original comments in GEN 19: they will have info for 

us shortly.

A letter was submitted to the Committee by Mr. Marc Buttler (Emerson Micro Motion) and will be posted 

to the WWMA website.
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The WWMA S&T Committee recommends that this Block be assigned a Developmental status. The 

Committee recommends that item GEN-19.1 be inserted into Block 7. 

Southern Weights and Measures Association

During the 2021 Annual Meeting Open Hearing Mr. Oppermann (Seraphin) stated that this item is related 

to Gen 19.1. and should not move forward unless Gen 19.1 moves forward as well. 

This Committee recommends this item be assigned Developing status. 

Northeastern Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Mr. Henry Opperman (Seraphin) commented with clarification from Mr. Bob Murnane (Seraphin) that this 

item is in conjunction with Gen 19 and with the changes outlined in Gen 19 (see comments). He 

recommends this item to be forwarded as a Developing item. 

The NEWMA Specifications and Tolerances Committee recommends that this item be given a Developing 

Status. 

During the 2022 Annual Meeting Open Hearing no comments were heard from the body on this item, 

however, the Committee recognizes the need to further develop this block.

Central Weights and Measures Association

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mr. Henry 

Opperman (Weights and Measures Consultants) stated that if GEN 19.1 were to pass then CLM 22.1 and 

CDL 22.1 would need to be voted on as well. Mrs. Tina Butcher (NIST OWM) thinks original formula is 

correct, whereas modified formula would not put a limit. Believes it needs more work. Mr. Robert Murnane

(Seraphin) recommended that the item stay as Developing and be combined with GEN 19.1.

CWMA S&T Committee recommends that the item be Developing.

During 2022 Annual Meeting Open Hearing, Mr. Bob Murnane (Seraphin) commented that it should remain 

Developing, can’t move to Voting item unless OTH-22.1 does move to Voting.

The CWMA S&T Committee recommends this moves forward as a Voting item, with the understanding 

that Block 8 must first pass. 

ITEM BLOCK 8 (B8) D G-T.5. TOLERANCES ON TESTS WHEN TRANSFER STANDARDS 

ARE USED., APPENDIX A, SECTION 3.2. TOLERANCES FOR 

STANDARDS., AND APPENDIX D – DEFINITIONS: STANDADS, FIELD., 

TRANSFER STANDARD. AND STANDARD, TRANSFER. APPENDIX A: 

FUNDAMENTAL CONSIDERATIONS, 3. TESTING APPARATUS 

B8: GEN-19.1 D G-T.5. Tolerances on Tests When Transfer Standards are Used., Appendix A, Section 

3.2. Tolerances for Standards., and Appendix D – Definitions: standards, field., transfer 

standard. and standard, transfer.
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B8: OTH-22.1 D Appendix A: Fundamental Considerations, 3. Testing Apparatus

(Note: These proposals are a combined modification of the 2021 S&T Agenda Block 1 Items GEN-19.1 

and OTH-22.1. Since the S&T Committee has changed item GEN-19.1 from “assigned” to “developing,” 

the submitter has worked with NIST OWM to revise and combine the original proposals of GEN-19.1 and 

OTH-22.1 to address discussions within the NCWM Field Standards Task Group and other comments 

received at the regional weights and measures meetings on the proposals. These items are related, so they 

are presented together. These OWM and Seraphin proposals were submitted to the S&T Committee just 

before the 2022 Interim Meeting.

Note: The joint OWM and Seraphin proposals submitted to the S&T Committee just before the 2022 

Interim Meeting were updated with two changes at the request of the Submitters following the 2022 Interim 

Meeting. The first change is in the definition of “Standard, Field.” The words “(typically one year)” were 

replaced with “(as determined by the Director)”. The second change was to add the words “to the 

International System of Units (SI)” in the section 3.1.3. of the Fundamental Considerations. These two 

changes are reflected in the items below.) 

Source: The NIST Office of Weights and Measures and Seraphin Test Measure Company have combined 

their previously separate proposals into a single proposal.

Purpose and Justification:

(a) Add a tolerance statement to the General Code that applies whenever a Type 2 transfer standard is 

used;

(b) Clarify in the Fundamental Considerations (Appendix A of Handbook 44) that the authority to 

approve field test standards rests with the regulatory official and that specific types of field test 

standards need not be identified in the body of a Handbook 44 Code in order to be approved by the 

weights and measures director;

(c) Add text to Section 3.2. Tolerances for Standards of the Fundamental Considerations (Appendix A 

of Handbook 44) to recognize the wide range of transfer standards already recognized in Handbook 

44, explain the critical differences between field standards and transfer standards, and to specify 

the formula to be used to calculate the device tolerance when the uncertainty of the transfer standard 

exceeds the one-third requirement; and

(d) Add definitions to Appendix D of Handbook 44 for field standard and Type 1 and Type 2 transfer 

standards that identify the critical characteristics for field and transfer standards.

Footnote 2 in the Fundamental Consideration of NIST Handbook 44 already provides a statement regarding 

the authority of the Director to approve field test standards or equipment, OWM believes including 

additional information regarding the essential elements of traceability and a reference to specific 

measurement practices would be helpful to both emphasize that authority and provide guidance to Directors 

and industry regarding the selection of appropriate field test standards. 

NIST OWM recommends the guidance originally included in Footnote 2 along with the additional 

references to the “Essential Elements” described above are best included in the body of Section 3 for clarity 

and ease of use. Consequently, OWM recommends deleting the existing Footnote 2 and incorporating its 

contents into the body of Section 3.
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OWM also believes that some may erroneously believe that field test standards must be specifically listed 

within a NIST Handbook 44 code in order to be used in the inspection and testing of devices covered by 

that code. Providing a clear statement that this is not the case along with a reference to the required criteria 

may help alleviate this misunderstanding.

A tolerance statement is added to the general code that addresses uncertainties of Type 2 Transfer standards

since they do not meet the NIST Handbook 44 Fundamental Consideration that state “When the standard 

is used without correction, its combined error and uncertainty must be less than one-third of the applicable 

device tolerance”. Several equations were considered to included an OIML equation. After discussion an 

alternative equation was agreed upon. An assessment of the two equations, the 2/3 Formula: Increased 

MPE = (2/3 x MPE + U) with an upper limit of UMAX = 2/3 MPE and the OIML Formula: Reduced MPE 

= (4/3 × MPE – U) are provided below:

The OIML formula and the 2/3 formula are similar, but they take different approaches to establish the 

tolerances for the device under test. The 2/3 formula is more logical, more technically consistent with the 

Handbook 44 concept of Type 2 transfer standards, and it is easier to understand. The 2/3 formula combines 

the tolerance that remains to be used by the commercial device with the growing uncertainty of the T2TS 

into one total tolerance value, whereas the OIML Reduced MPE calculates only the tolerance applied to 

test of the commercial meter under test. When Type 2 transfer standards are used in the field, the 

uncertainties associated with the T2TS should be recorded on the report form or a copy of the calibration 

certificate should be left with the test report, so the uncertainty values are available on site and can be used 

in an analysis should the tests with another T2TS generate different results.

The most accurate reference standard that is available should always be used for any field test. However, 

when the only practical option for a field test that is available is a Type 2 transfer standard, the 2/3 formula 

will err in favor of the commercial device to avoid failing a device that should have passed. Conversely, 

the OIML Reduced MPE might result in failing a commercial device that would have passed had a more 

accurate (e.g., Type 1 transfer or field) reference standard been available to use for the test.

Field standards are intended to have an error and uncertainty less than or equal to 1/3 of the tolerance 

applied to the commercial device under test. When a Type 2 transfer standard has an uncertainty slightly 

greater than 1/3 of the tolerance, then, using the 2/3 formula, the total tolerance applied to the device under 

test increases above the H44 tolerance by the amount that the uncertainty associated with the Type 2 transfer 

standard exceeds the 1/3 limit, thereby establishing a total tolerance slightly greater than the NIST 

Handbook 44 tolerances specified in the applicable codes and keeping the portion of the tolerance that 

remains allocated to the device under test at a constant level equal to 2/3 of the NIST Handbook 44

tolerance.

Type 2 Transfer Standards: Uncertainty is Added to the Tolerance

When the uncertainty associated with a T2TS exceeds 1/3 of the tolerance applied to the device under test, 

the uncertainty of the T2TS is recognized in the field test result by increasing the tolerance that is applied 

to the device under test. The OIML formula and the 2/3 formula take different approaches to increasing 

the tolerance for the device under test. 
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OWM Executive Summary for Item Block 8 (B8) G-T.5. Tolerances on Tests When 

Transfer Standards Are Used, Appendix A, Section 3.2. Tolerances for Standards., and 

Appendix D – Definitions: Standards, Field., and Standard, Transfer. Appendix A: 

Fundamental Considerations, 3. Testing Apparatus

OWM Recommendation: The submitters agree that these items, GEN-19.1 and OTH-22.1 are fully 

developed and requested that this S&T committee consider that Block 8 item be a Voting Item in 2023.

• State and industry have a need to use various types of test standards to evaluate commercial devices 

installed in the marketplace. NIST OWM recognizes the need to use various standards to test 

commercial devices and support the use of these standards when test data supports its use.

• Block 8 clarifies the use and definition of three types of standards to be included in NIST HB 44: (1) 

Fields Standards, (2) Type 1 Transfer Standards and (3) Type 2 Transfer Standards; it provides an 

equation that should be used to calculate the tolerances when Type 2 transfer standards are used; 

provides definitions for Field Standards, Type 1 Transfer Standards and Type 2 Transfer Standards, 

and provides clarification that the State Director has the authority to approve the use of standard and 

that specific requirements in NIST HB 44 code are not necessary to approve a standard for use. 

 

• Two items, LPG-15.1 and MFM-15.1 in the Interim Meeting Report (Publication 16), include a 

purpose statement that the proposals are added to allow field standard meters to be used to test and 
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place into service dispensers and delivery system flow meters. Block 8 items clarify what has always 

been recognized in NIST HB 44 concerning the responsibility for acceptance of a standard and notes 

that specific code changes are not necessary for a field standard to be adequate for use.

• In addition to the changes in Block 8, a new form 15 for the 2023 cycle, which is not included in the 

2022 Publication 16 and has not been addressed separately in the 2022 NIST OWM Technical 

Analysis, has been circulated to the Spring 2022 Regional Associations (NEWMA and CWMA)

• This new Form 15 adds a General Code requirement so that rather than revising a specific code in 

Handbook 44 every time a new field or transfer standard is proposed or developed, an overall 

statement in the General Code recognizes the use of other field and transfer standards that meet the 

requirements for use as field or transfer standards. The proposal is as follows:

G-N.3. Test Methods. – Permissible test methods for verifying compliance of weighing and 

measuring systems with the provisions of the General Code and Specific Codes include, but are 

not limited to, test methods and apparatus that have been approved by the State Director of 

weights and measures as outlined in Appendix A - Fundamental Considerations, Section 3. 

Testing Apparatus.

• NIST OWM also observed that the definitions in Block 8 should include appropriate references to 

the NIST HB 44 codes.

Table 3. Summary of Recommendations

BLOCK 8 (B8) ITEM GEN-19.1 – G-T.5. Tolerances on Tests When Transfer Standards are Used., 

Appendix A, Section 3.2. Tolerances for Standards., and Appendix D – Definitions: standards, 

field., transfer standard. and standard, transfer

V D W A I Notes* Comments 

Submitter 

Seraphin & 

OWM

 1

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes
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Table 3. Summary of Recommendations

BLOCK 8 (B8) ITEM GEN-19.1 – G-T.5. Tolerances on Tests When Transfer Standards are Used., 

Appendix A, Section 3.2. Tolerances for Standards., and Appendix D – Definitions: standards, 

field., transfer standard. and standard, transfer

Industry

Supporting Information 

from Seraphin Test 

Measure Co. (04-03-

2020)

Comments from 

Emerson-Micro Motion 

(09-27-2021)

Updated Proposal from 

Seraphin Test Measure 

Co. (01-06-2022)

Formula Explanation – 

Seraphin Test Measure 

(06-17-2022)

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

 5 − No recommendation or not considered

Table 3. Summary of Recommendations

BLOCK 8 ITEM (B8) OTH-22.1 Appendix A: Fundamental Considerations, 3. Testing Apparatus

V D W A I Notes* Comments

Submitter 

OWM 

WWMA 

SWMA 

NEWMA 

CWMA 

NCWM 

Letters of Support Letters of Opposition Notes
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Table 3. Summary of Recommendations

BLOCK 8 ITEM (B8) OTH-22.1 Appendix A: Fundamental Considerations, 3. Testing Apparatus

V D W A I Notes* Comments

Industry

Updated Proposal from 

Seraphine Test 

Measure Co. (01-06-

2022)

Manufacturers

Retailers and Consumers

*Notes Key:

1 − Submitted modified language

2 − Item not discussed

3 − No meeting held

4 − Not submitted on agenda

5 − No recommendation or not considered

B8: GEN-19.1 D G-T.5. Tolerances on Tests When Transfer Standards are Used., Appendix 

A, Section 3.2. Tolerances for Standards., and Appendix D – Definitions: standards, field., transfer 

standard. and standard, transfer.

Amend Handbook 44, General Code as follows: 

G-T.5. Tolerances on Tests When Type 2 Transfer Standards Are Used. – When Type 2 

transfer standards are used, the following formula shall be used to compute the tolerance 

applicable to the device under test:

Increased MPE = (2/3 x MPE + U)

with an upper limit of UMAX = 2/3 MPE

Where MPE is the basic tolerance that applies when using a basic reference standard; and

U = uncertainty associated with the Type 2 transfer standard.

The increase in the applied tolerance when using a Type 2 transfer standard applies only to 

the basic tolerances for devices as defined in Handbook 44; that is acceptance, maintenance 

and minimum tolerances. Note that the repeatability tolerance and the special test tolerances 

are NOT increased.

Codes 5.56.(a) Grain Moisture Meters, 5.56.(b) Grain Moisture Meters, and 5.57. NearInfrared Grain Analyzers are exempt from this requirement because NIST Handbook 159

has requirements for monitoring and retesting grain samples to ensure adequate stability and 

the tolerances for the devices under test already incorporate the uncertainty associated with 

the use of grain samples as transfer standards. The code 2.21. Belt-Conveyor Scale Systems 

Code is also exempt because relative and absolute tolerances are included in the code.

Amend Handbook 44 Appendix D – Definitions as follows.
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Standard, Field. – A physical artifact, static or dynamic measurement device or a reference

material that (a) meets the requirements of the Fundamental Considerations, Section 3.2., (b) 

is stable (accurate and repeatable) over an extended period of time (as determined by the 

Director), (c) is valid (corrections that may be used) over the range of environmental and 

operational parameters in which the commercial measuring devices are used, and (d) is 

traceable to the reference or working standards through comparisons, using acceptable 

laboratory procedures. [3.34, 3.38, 3.39, x.xx, x.xx...]

(Added 202X) 

transfer standard. – A measurement system designed for use in proving and testing cryogenic 

liquid-measuring devices. [3.38] 

Standard, Transfer, Type 1 and Type 2. − A physical artifact, static or dynamic measurement 

device or a reference material that is proven to be stable (accurate and repeatable) for a short 

time under the limited environmental and operational conditions during which the transfer 

standard is used. A Type 1 transfer standard is a transfer standard that meets the one-third 

accuracy requirement for a short time over a limited range of environmental conditions 

and/or a limited range of operating conditions in which it is used. A Type 2 transfer standard 

is one that does not meet the one-third requirement and may not be stable or valid over an 

extended time period or over wide ranges of environmental or operating conditions. (3.34, 

3.38, 3.39, x.xx, x.xx...]

(Added 202X)

B8: OTH-22.1 D Appendix A: Fundamental Considerations, 3. Testing Apparatus

Amend Handbook 44, Appendix A: Fundamental Considerations as shown below. Delete Footnote 2 

referenced in Section 3. Testing Apparatus of NIST Handbook 44 Appendix A, Fundamental 

Considerations, moving portions of the footnote into Section 3.1 as part of the proposed changes to Section 

3.1 shown above. Note that no changes are proposed to Footnote 1.

2 Recommendations regarding the specifications and tolerances for suitable field standards may 

be obtained from the Office of Weights and Measures of the National Institute of Standards and 

Technology. Standards will meet the specifications of the National Institute of Standards and 

Technology Handbook 105-Series standards (or other suitable and designated standards). 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.

3.1.Adequacy.2 – Tests can be made properly only if, among other things, adequate testing apparatus 

is available. Testing apparatus may be considered adequate only when it is properly designed for its 

intended use, when it is so constructed that it will retain its characteristics for a reasonable period under 

conditions of normal use, when it is available in denominations appropriate for a proper determination 

of the value or performance of the commercial equipment under test, and when it is accurately 

calibrated.

3.1.1. Essential Elements of Traceability. To ensure that field test standards and test 

methods provide for measurements that are traceable to the International System of Units 

(SI), through NIST or other National Metrology Institutes, they must satisfy the “Essential 

Elements of Traceability.” As explained in NIST IR6969 GMP-13 Good Measurement 

Practice for Ensuring Metrological Traceability, these elements include the following.
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• Realization of SI Units

• Unbroken Chain of Comparisons

• Documented Calibration Program

• Documented Measurement Uncertainty

• Documented Measurement Procedure

• Accredited Technical Competence

• Measurement Assurance

3.1.2. Specifications for Standards. Standards will meet the specifications of the National 

Institute of Standards and Technology Handbook 105-Series standards or other appropriate 

designated documentary standards (e.g., ASTM, ASME, etc.). Recommendations regarding 

the specifications and tolerances for suitable field standards may be obtained from the Office 

of Weights and Measures of the National Institute of Standards and Technology.

3.1.3. Authority for Approving Field Test Standards and/or Equipment. 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. Specific types of field test standards 

are not required to be identified in a NIST Handbook 44 code in order to be considered 

suitable. Provided the standards meet the “Essential Elements of Traceability” (described in 

Section 3.1.1. above) that help ensure the standards are suitable and capable of supporting 

measurements traceable to the International System of Units (SI) through NIST or other 

National Metrology Institutes, they need only be approved by the Director.

3.2.Tolerances for Standards. – Except for work of relatively high precision, it is recommended that 

the accuracy of field standards used in testing commercial weighing and measuring equipment be 

established and maintained so that the use of corrections is not necessary. When the field standard is 

used without correction, its combined error and uncertainty must be less than one-third of the applicable 

device tolerance.

Device testing is complicated to some degree when corrections to standards are applied. When using 

a correction for a standard, the uncertainty associated with the corrected value must be less than onethird of the applicable device tolerance. The reason for this requirement is to give the device being 

tested as nearly as practicable the full benefit of its own tolerance.

Whenever possible and practical, field standards should be used to test commercial devices. 

However, where it is impractical or unduly cumbersome to use field standards, transfer 

standards may be used. There are two categories of transfer standards. The critical criteria that 

distinguish between these standards are: (1) the accuracy and uncertainty of the standard; (2) 

the stability as a standard over an extended period; and (3) proven validity or performance of 

the standard over the range of environmental and operational conditions in which the standard 

may be used.

A “field standard” is one that meets the one-third requirement mentioned earlier in this section. 

Additionally, the field standard maintains its validity or stability as a standard over an extended 
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period (defined based on data of the standard’s stability by an authorized metrology lab or as 

specified by the Director) and is known to maintain its value as a standard over the full range of 

environmental conditions and the range of operating conditions in which the standard may be 

used to test commercial weighing and measuring devices. Corrections, as documented by an 

authorized metrology laboratory, may be used.

Transfer standards do not meet one or more of these critical criteria. One category of transfer 

standards, which is referred to here as a “Type 1 transfer standard,” is a transfer standard that 

meets the one-third accuracy requirement for a short time, under a limited range of 

environmental conditions and/or a limited range of operating conditions. The accuracy of a Type 

1 transfer standard may have to be verified through testing each time it is used to verify that the 

desired accuracy and performance can be achieved when the Type 1 transfer standard is used 

under the limited environmental and operating conditions. When a Type 1 transfer standard is 

used, the basic tolerances specified for the commercial measuring devices are applied as specified 

in the applicable codes.

The second category of transfer standard, which is referred to here as a “Type 2 transfer 

standard,” is one that does not meet the one-third requirement. The Type 2 transfer standard 

must be stable and valid under the environmental or operating conditions in which it is used. The 

performance characteristics must be confirmed with sufficient data to properly characterize the 

uncertainty associated with the Type 2 transfer standard. When a Type 2 transfer standard is 

used, the tolerances applicable to the commercial weighing and measuring device must be 

increased to recognize the large uncertainty or corrections associated with the Type 2 transfer

standard. When commercial meters are tested using a Type 2 transfer standard, the tolerance 

applied to the meter under test shall be determined as specified in the General Code.

(Added 202X)

3.3.Accuracy of Field Standards. – Prior to the official use of testing apparatus, its accuracy should 

invariably be verified. Field standards should be calibrated as often as circumstances require. By their 

nature, metal volumetric field standards are more susceptible to damage in handling than are standards 

of some other types. A field standard should be calibrated whenever damage is known or suspected to 

have occurred or significant repairs have been made. In addition, field standards, particularly 

volumetric standards, should be calibrated with sufficient frequency to affirm their continued accuracy, 

so that the official may always be in an unassailable position with respect to the accuracy of his testing 

apparatus. Secondary field standards, such as special fabric testing tapes, should be verified much more 

frequently than such basic standards as steel tapes or volumetric provers to demonstrate their constancy 

of value or performance.

Accurate and dependable results cannot be obtained with faulty or inadequate field standards. If either 

the service person or official is poorly equipped, their results cannot be expected to check consistently. 

Disagreements can be avoided and the servicing of commercial equipment can be expedited and 

improved if service persons and officials give equal attention to the adequacy and maintenance of their 

testing apparatus.

NIST OWM Detailed Technical Analysis: 

State and industry have a need to use various types of test standards to evaluate commercial devices installed 

in the marketplace. NIST OWM recognizes the need to use various standards to test commercial devices 

and support the use of these standards when test data supports its use. Several proposals for changes to 
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NIST HB 44 have been considered to address the use of these standards. Some were to address terminology 

for various types of standards in NIST HB 44. Other proposals were to provide specific requirements for 

some codes in NIST HB 44 for the purpose of recognizing these standards in the handbook, but the 

responsibility for recognition of standards is already address in the fundamental consideration section in 

NIST HB 44. These proposals also included varying terms used to describe these standards and were 

subsequently all combined as a Block item and assigned to a task group. With limited success as a block 

item, it was decided to separate these items into their original block and individual items for consideration, 

some of the items were withdrawn. Block 8 items are a combined modification of the 2021 S&T Agenda 

Block 1 Item GEN-19.1 and OTH-22.1. With the S&T Committee changes to the status of item GEN-19.1 

from “assigned” to “developing,” the submitter, Seraphin and NIST OWM seeing the need to add 

clarification to NIST HB 44 for the different terms used to address standards that are used to test commercial 

devices and the need to provide clarification as to what is needed for States to accept various types of 

standards, worked together to develop Item Block 8. These proposals were revised to address discussions 

within the NCWM Field Standards Task Group and other comments received at the regional weights and 

measures associations meetings and the 2022 Interim Meeting. There is also a companion item Block 7 that 

helps to clarify the use of the term transfer standards in NIST HB 44.

Block 8 clarifies the use and definition of three types of standards to be included in NIST HB 44: (1) Fields 

Standards, (2) Type 1 Transfer Standards and (3) Type 2 Transfer Standards; it provides an equation that 

should be used to calculate the tolerances when Type 2 transfer standards are used; provides definitions for 

Field Standards, Type 1 Transfer Standards and Type 2 Transfer Standards, and provides clarification that 

the State Director has the authority to approve the use of standard and that specific requirements in NIST 

HB 44 code are not necessary to approve a standard for use. 

Although 3 types of standards are to be specified in NIST HB 44, language has been added in Block 8 such 

that whenever possible and practical, field standards should be used to test commercial devices. Definitions 

are provided for the three different types of standards. Separating the standards into 3 types helps to 

determine what specifications should be used for the standards combined error and uncertainty or whether 

the tolerances should be increased to account for the error in the standard. Both Field Standards and Type 

1 Transfer standards must comply with the current Fundamental Considerations in NIST HB 44 that state 

“When a Standard is used without correction, its combined error and uncertainty must be less than onethird of the applicable device tolerance”. This allows the device under test to have more than 2/3 of the 

tolerance associated with the test. Type 2 Transfer Standards do not meet the one-third requirement and 

may not be stable or valid over an extended time-period or over wide ranges of environmental or operating 

conditions. With the inability to meet the one-third requirements for the uncertainty in the standard that 

Field Standards and Type 1 Transfer Standard are required to meet, an equation was added to the general 

code for all Type 2 Transfer Standards in NIST HB 44 to multiply the basic tolerance (the applicable 

tolerance, maintenance, acceptance, or special test tolerances by 2/3 and adding the uncertainty of the 

standard. This increases the total tolerance when using a Type 2 transfer standard to account for the 

uncertainty of the standard. 

Although a larger tolerance is used to account for the uncertainty in Type 2 standards, allowing an unlimited 

amount of uncertainty to be added to the tolerance adds an open-ended amount of uncertainty to the 

tolerance and the larger the tolerance that is allowed the more lead way is given to the device under test and 

the more disadvantage to the customer. As such a stipulation was added that the maximum limit for the 

uncertainty of type 2 standards must be 2/3 of the MPE. The proposed equation provides a uniform method 

for considering the uncertainties associated with Type 2 Standards. An example of calculating the equation 

is provided below. 
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Increased MPE = (2/3 x MPE + U)

with an upper limit of UMAX = 2/3 MPE

Example Calculation

Increased MPE = (2/3 x 0.01 + 0.005)

= 0.01166

In this example the UMAX does not exceed 2/3 MPE which = 0.007

Mr. Henry Oppermann of Seraphin provided an analysis of the equation which is provided in the 

Justification of this Technical Analysis. 

This Block also helps to clarify that the Director has the authority to approve Standards for use within a 

jurisdiction. This information is already included in a footnote in the Fundamental Considerations but has 

been moved to Section 3 in the Fundamental Considerations. Language was also added to clarify that 

specific language is not needed in various NIST HB Codes in order that these standards be accepted. Two 

items, LPG-15.1 and MFM-15.1 in the Interim Meeting Report (Publication 16), include a purpose 

statement that the proposals are added to allow field standard meters to be used to test and place into service 

dispensers and delivery system flow meters. Block 8 items clarify what has always been recognized in 

NIST HB 44 concerning the responsibility for acceptance of a standard and notes that specific code changes 

are not necessary for a standard to be adequate for use. Please see additional NIST OWM concerns with 

items LPG-15.1 and MFM-15.1 in the NIST OWM Technical Analysis for these items. 

In addition to the changes in Block 8, a new Form 15 for the 2023 cycle which is not included in the 2022 

Publication 16 and has not been addressed separately in the 2022 NIST OWM Technical Analysis, has been 

circulated to the Spring 2022 Regional Associations (NEWMA and CWMA) that will also impact LPG15.1 and MFM-15.1 and Block 7 items. This proposal adds a General Code requirement so that rather than 

revising a specific code in Handbook 44 every time a new field or transfer standard is proposed or 

developed, an overall statement in the General Code recognizes the use of other field and transfer standards 

that meet the requirements for use as field or transfer standards is proposed as follows:

G-N.3. Test Methods. – Permissible test methods for verifying compliance of weighing and measuring 

systems with the provisions of the General Code and Specific Codes include, but are not limited to, 

test methods and apparatus that have been approved by the State Director of weights and measures 

as outlined in Appendix A - Fundamental Considerations, Section 3. Testing Apparatus.

For those who believe a specific statement in Handbook 44 is needed to recognize additional field and 

transfer standards, the proposed addition of G-N.3. will provide the reference they want without the need 

to change individual codes on a regular basis to recognize each particular field or transfer standard. 

The submitters agree that these items, GEN-19.1 and OTH-22.1 are fully developed and requested that this 

S&T Committee consider that this combined item be a Voting Item in 2023.

Summary of Discussions and Actions:

At the 2022 Interim Meeting there was discussion concerning specifying a 1-year length of time for the 

stability of a field standard. The concern was whether or not this was an appropriate length of time and 
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how a specific length of time for a standards stability could change due to many factors. Some expressed 

concerns with more time needed to review the latest edition of the proposal. NIST and Seraphin agreed to 

further develop the item and NIST OWM requested that both GEN-19.1 and the OTH-22.1 be combined. 

During their work session, the Committee agreed to combine both GEN-19.1 and OTH-22.1 and agreed to 

a developing status for this item. For more information or to provide comment, please contact:

Mr. Robert Murnane

Seraphin Test Measure Company

A Division of Pemberton Fabricators, Inc.

(609) 267-0922, rmurnane@pemfb.com 

or

Ms. G. Diane Lee

NIST Office of Weights and Measures

diane.lee@nist.gov

Regional Association Reporting: 

Western Weights and Measures Association

(B8: GEN-19.1)

At the 2021 WWMA Open Hearings the following comments were heard: 

Mr. Marc Buttler (Emerson Micro Motion): Regards to the fine work of the work group and authors of 

form 15, he finds it useful and helpful by augmenting the existing wording to add clarity as we work forward 

to more practical testing. He wanted to comment on whether the underlying principle of affording 

additional tolerance not capable of meeting the 1/3rd. In the language there is an equation (lower down in 

the proposal) reduced MPE. This is intended to penalize the tolerance of the device and not give additional 

leeway. Further into the justification it references an established principle that says that additional tolerance 

is afforded when complex. A better equation would be to take the MPE x 2/3 PLUS and not minus. This 

avoids jurisdictions having different uncertainty testing to different tolerances. He can prepare a written 

summary of his comments and will send to us.

Mr. Bob Murnane (Seraphin): Seraphin proposed this. There is a lack of definitions. This comes into play 

in block 5. This was put in to clarify and give definite definitions to field and transfer standards. He hopes 

this clarifies multiple items on the agenda.

Mr. Russell Vires (Scale Manufactures Association): this item has been around for a while and was part of 

block 1. It has been pulled out and changed. The SMA has made comments in the past to support this item, 

but at this point they will meet in November and review; they have not been able to review the substantial 

changes yet. They have no position as of now. This needs to remain developing to allow stakeholders the 

opportunity to review.

Ms. Diane Lee (NIST OWM): wants to expand on Mr. Vires’ comments. This was included in a block 

with terminology for standards, (master meter, transfer standard or field standard). She questioned whether 

the transfer standards could meet the 1/3 standard. NIST has an analysis from the Annual Meeting that will 

address some of the issues; however, they have not met as a group yet. We can look online on NCWM and 

look forward to them providing additional info. (Previous analysis is available on the NCWM website).
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Mr. Kurt Floren (Los Angeles County, California): he commented on the proposed definition of field 

standard (S&T 7). He thinks it is better, but raises an issue that there is a distinction between volumetric 

and gravimetric. The existing language spoke to the calibration and certification in the lab. Field standards 

are tested under all environmental conditions and range of operating conditions. In a lab setting, there are 

conditions that need to be very strict. He's concerned that it says that it's known to maintain. Question: are 

we thinking more from a volumetric standpoint (temperature changes, etc.) that’s not really a concern with 

a mass standard. Thinks that there will be challenges in the future on pass/fail, and question all of the 

environmental criterial that the standards were tested to. Requesting (please) take into consideration the 

environmental factors (lab or/vs. field) and how this would relate to an enforcement action. 

The WWMA S&T Committee recommends that this item should remain Developmental in status. The 

Committee recommends that the submitter works with NIST OWM and commentators above to resolve 

issues presented. A letter was submitted to the Committee by Mr. Marc Buttler (Emerson Micro Motion) 

and will be posted to the NCWM website. The Committee also recommends that consideration be made 

that this item be included in Block 7.

(B8: OTH-22.1)

During the 2021 Annual Meeting Open Hearing the following comments were heard:

Mr. Michael Keilty (Endress + Hauser): 3.1.1 on pg. S&T 112, line 2: unnecessary language: “likely 

through NIST” is not appropriate. In 3.1.2 : “standards will meet the... or other appropriate.... ASTM 

ASME” NIST HB105 is not consensus standards and we should not be referring to that. Traceability is not 

solely owned by NIST. Speaks about international traceability (Switzerland, Canada, etc..). Recommends 

Developing.

Mrs. Tina Butcher (NIST OWM): Submitter: NIST is not the only one for traceability - key here is making 

sure that due diligence that essential elements of traceability have been addressed. Authority rests with 

W/M director. Item 3.12: question ab. HB105: this requirement is simply taking the already existing 

language and moving it up into the main body. This is to clarify where authority rests (W/M directors). 

Clarifies what is needed to be looked at.

Mr. Matt Douglas (California - DMS): They support this item.

Mr. Randy Jennings (Retired, Tennessee, Rep's himself): supports comments made by Mr. Keilty. Wants 

to be careful about bringing forward anything that can take away options.

Ms. Cadence Matijevich (Nevada): seeking clarification from Mrs. Butcher: clarification on 

traceability/distinction, SI vs NIST, in 3.1.1: we say traceable to international system, in 3.1.3: says 

traceable to NIST. Why is there a discrepancy in traceability verbiage? Is there a specific reason to limit 

to NIST in 3.1.3?

Mrs. Butcher (NIST OWM): they tried to preserve the language already in footnote 2 and just bring it up 

into the body. Trying to emphasize that the director has the authority. Tried to provide a link between 

3.1.1 and 3.1.3. Could say traceable to SI likely through NIST.

Mr. Michael Keilty (Endress + Hauser): they say traceability is through national standards and they feel 

that that covers it all.

The WWMA S&T Committee recommends that this be assigned a Developmental status. 
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Southern Weights and Measures Association

(B8: GEN-19.1)

During the 2021 Annual Meeting Open Hearing, Mr. Henry Oppermann (Seraphin) explained the 

differences between Field Standards, Type 1 and Type 2 Transfer Standards, and expressed support for a 

proposed change that originated in the Western. 

Mr. Tim Chesser (Arkansas) questioned what “sufficient data” would be once a device is placed into service 

as a Standard, and how often it would need to be reverified.

Mr. Oppermann responded to Mr. Chesser stating that the Master Meter Task Group must evaluate the 

performance of these devices and create calibration and performance requirements in the future. 

Mr. Russ Vires (speaking on behalf of the Scale Manufacturers Association) stated that they have no 

position at this time. 

Mr. Russ Vires (speaking on behalf of Mettler Toledo) stated that he believes this is in conflict with Block 

1, and would recommend it continue with a Developing status. 

Mr. Michael Keilty (Endress + Hauser) assured Mr. Chesser that any devices used as a Field Standard 

would have a traceable chain of metrology. 

This Committee recommends that this item remain Assigned pending the Workgroup finding a new 

Chairperson. 

(B8: OTH-22.1)

During the 2021 Annual Meeting Open Hearing, Mr. Keilty (Endress+Hauser) stated that this item is a 

proposal by NIST to change some language in Appendix A of Handbook 44. The changes suggested are 

to strike “likely through NIST,” in section 3.1.1., “the National Institute of Standards and Technology 

Handbook 105-Series standards or other” in section 3.1.2., as well as to strike “NIST” in section 3.1.3. and 

replace it with “International System of Units (SI)”. He does not feel that Handbook 105 is a consensus 

document. 

Mr. Oppermann (Seraphin) stated that he would like to work with NIST to combine this item with GEN 

19.1, and recommended moving it forward with a Developing status. 

This Committee agrees that this item should be reworded or possibly combined with Gen 19.1 and 

recommends this item be assigned a Developing status.

Northeastern Weights and Measures Association

(B8: GEN-19.1)

During the 2021 Interim Meeting Open Hearings, the following comments were heard: Henry Opperman 

(W&M Consulting/Seraphin) Commented that they are updating the formula in the proposal due to the 

feedback received from the Western Weights and Measures Association and recommended a Developing 

Status. Updates can be found on the NCWM website. 
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Lou Straub representing the SMA agreed with a Developing Status and reminded us that SMA positions 

have been posted on the NCWM website.

The NEWMA Specifications and Tolerances Committee recommends that this item be given a Developing 

Status.

(B8: OTH-22.1)

During the 2021 Interim Meeting Open Hearing the following comments were heard.

Ms. Juana Williams (NIST OWM) commented: 

• NIST OWM submitted this item to:

o Further emphasize the statement currently in the Fundamental Considerations that authority 

rests with the Director to approve standards.

o Provide additional details to assist in the assessment and approval of a standard for use in 

testing commercial weighing and measuring systems.

 This includes recognizing the need to verify that certain essential elements of 

traceability have been met and a listing of those elements.

Based on comments heard at the WWMA, NIST would like to modify the language in the proposed 

3.1.3. Authority for Approving Field Test Standards and/or Equipment to align the language with that 

in the proposed 3.1.1. Essential Elements of Traceability; the proposed change will mirror the 

statement in 3.1.1. that that traceability to the SI can be establish through entities other than NIST.

3.1.3. Authority for Approving Field Test Standards and/or Equipment. 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. Specific types of field test standards are not required 

to be identified in a NIST Handbook 44 code in order to be considered suitable. Provided the 

standards meet the “Essential Elements of Traceability” (described in Section 3.1.1. above) that 

help ensure the standards are suitable and capable of supporting measurements traceable to the SI, 

likely through NIST, they need only be approved by the Director.

• OWM notes that work underway in the NIST USNWG on Field Reference Meters may result in 

additional input to this section of the Handbook and possibly, though not necessarily, other 

sections. In the meantime, the proposed changes to this section will clarify that test standards need 

not be specified by name in specific codes, unless there is language that would otherwise impact their 

use.

Mr. Michael Keilty (Endress + Hauser Flowtec) comments below: he is suggesting the removal of yellow 

highlighted portions that are referencing NIST and the change reflected in 3.1.3.(blue highlighted) He 

believes that NIST is relevant, but not the only avenue for traceability. 

3.1.1. Essential Elements of Traceability. To ensure that field test standards and test 

methods provide for measurements that are traceable to the International System of Units 

(SI), likely through NIST, they must satisfy the “Essential Elements of Traceability.” As 
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explained in NIST IR6969 GMP-13 Good Measurement Practice for Ensuring Metrological 

Traceability, these elements include the following.

• Realization of SI Units

• Unbroken Chain of Comparisons

• Documented Calibration Program

• Documented Measurement Uncertainty

• Documented Measurement Procedure

• Accredited Technical Competence

• Measurement Assurance

3.1.2. Specifications for Standards. Standards will meet the specifications of the National 

Institute of Standards and Technology Handbook 105-Series standards or other appropriate 

designated documentary standards (e.g., ASTM, ASME, etc.). Recommendations regarding 

the specifications and tolerances for suitable field standards may be obtained from the Office 

of Weights and Measures of the National Institute of Standards and Technology.

3.1.3. Authority for Approving Field Test Standards and/or Equipment. 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. Specific types of field test standards 

are not required to be identified in a NIST Handbook 44 code in order to be considered 

suitable. Provided the standards meet the “Essential Elements of Traceability” (described in 

Section 3.1.1. above) that help ensure the standards are suitable and capable of supporting 

measurements traceable to NIST the International System of Units (SI), they need only be 

approved by the Director.

Mr. Lou Sakin (Hopkinton/Northbridge, Massachusetts) commented that he believes NIST OWM has a 

responsibility that is authorized by the Federal Dept. of Commerce. 

Mr. Bob Murnane (Seraphin) recommends Developing status, Mr. Henry Opperman (Weights and 

Measures Consulting) stated that NIST is relevant to this portion and Ms. Juana Williams (NIST OWM)

commented that NIST is indeed charged with responsibility from the Dept. of Commerce. 

The NEWMA Specifications and Tolerances Committee recommends that this item be given Developing 

Status with consideration given to the new language above.

(B8: GEN-19.1)

During the 2022 Annual Meeting Open Hearing, Mr. Bob Murnane (Seraphin) commented that the purpose 

of this proposal was to define Type 1 and Type 2 Transfer Standards. Originally the proposal had the OIML 

formula, but the formula only calculates the meter-to-meter tolerance and as the uncertainty associated with 

the transfer standard increases, the tolerance allocated to the commercial device gradually decreases. The 

submitter is now proposing a “2/3 Formula” where the calculation includes all the uncertainty associated 
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with the transfer standard and the tolerance allocated to the commercial meter never drops below 2/3 of the 

normal tolerance. Mr. Murnane requested that this proposal be given a voting status.

After hearing comments from the floor, the Committee recognized the need to further develop this block 

and recommended the block retain Developing status.

(B8: OTH-22.1)

Mr. Russ Vires (SMA) commented the SMA supports this item as Developing. He urged stakeholders to 

review the item and make comments available to submitter.

After hearing comments from the floor, the Committee recognized the need to further develop this block 

and recommended the block retain Developing status.

Central Weights and Measures Association 

(B8: GEN-19.1)

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mrs. Tina 

Butcher (NIST OWM) about working together with Seraphin to develop more. Mr. Robert Murnane

(Seraphin Test Measure) agreed with Mrs. Butcher and looked forward to working together. Should stay 

as developing. Mr. Lou Straub (SMA) has not had the chance to review but would be meeting in two weeks.

CWMA S&T Committee recommends item move forward as a Developing item.

(B8: OTH-22.1)

During the 2021 Interim Meeting Open Hearing the Committee heard comments from the floor. Mrs. Tina 

Butcher (NIST OWM) says item is ready to move forward as a voting item, but proposed a slight 

modification to the language based on comments heard at the WWMA. Mrs. Butcher requested the last 

sentence in the proposed 3.1.3. Authority for Approving Field Test Standards and/or Equipment be 

modified to add the statement “to the International System of Units (SI), likely through” immediately before 

the term “NIST.” This would align section 3.1.3. with the reference in proposed section 3.1.1. Essential 

Elements of Traceability and maintain the reference to NIST as is currently referenced by many 

jurisdictions’ weights and measures jurisdictions’ laws and regulations. The revised sentence in 3.1.3. 

would read as follows:

Provided the standards meet the “Essential Elements of Traceability” (described in Section 3.1.1. above) 

that help ensure the standards are suitable and capable of supporting measurements traceable to the 

International System of Units (SI), likely through NIST, they need only be approved by the Director.

Mr. Michael Keilty (Endress+Hauser) would like to see the comment Section 3.1.1. in the first sentence, 

strike “likely through NIST. Section 3.1.2. in the first sentence, strike “the National Institute of Standards 

and Technology Handbook 105-Series standards or other. Section 3.1.3. in the last sentence strike “NIST” 

and insert “International System of Units (SI)”. He recommends that this agenda item be revised as 

recommended and moved forward as a Voting item.

CWMA S&T Committee recommends that this item move forward as a Voting item with Mr. Michael 

Keilty’s (Endress+Hauser) recommendations. 
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(B8: GEN-19.1)

During the 2022 Annual Meeting Open Hearing, Mr. Bob Murnane (Seraphin) - transfer standard is already 

included in HB 44 but it isn’t defined. 

This doesn’t preclude the ability for The Director to approve transfer standards.

HB 44 doesn’t specify the frequency of testing intervals; cast iron vs stainless steel weights as an example. 

G.UR.4.1 already states the owner or operator must maintain the equipment, which includes the accuracy.

States have different interval requirements. Recommends moving to a Voting item.

Mr. Jan Konijnenburg (NIST OWM) - State and industry have a need to use various types of test standards 

to evaluate commercial devices installed in the marketplace. NIST OWM recognizes the need to use 

various standards to test commercial devices and support the use of these standards when test data supports 

its use. 

Block 8 clarifies the use and definition of three types of standards to be included in NIST HB 44: (1) Fields 

Standards, (2) Type 1 Transfer Standards and (3) Type 2 Transfer Standards; it provides an equation that 

should be used to calculate the tolerances when Type 2 transfer standards are used; provides definitions for 

Field Standards, Type 1 Transfer Standards and Type 2 Transfer Standards, and provides clarification that 

the State Director has the authority to approve the use of standard and that specific requirements in NIST 

HB 44 code are not necessary to approve a standard for use. 

Two items, LPG-15.1 and MFM-15.1 in the Interim Meeting Report (Publication 16), include a purpose 

statement that the proposals are added to allow field standard meters to be used to test and place into service 

dispensers and delivery system flow meters. Block 8 items clarify what has always been recognized in 

NIST HB 44 concerning the responsibility for acceptance of a standard and notes that specific code changes 

are not necessary for a field standard to be adequate for use. 

In addition to the changes in Block 8, a new form 15 for the 2023 cycle which is not included in the 2022 

Publication 16 and has not been addressed separately in the 2022 NIST OWM Technical Analysis but has 

been circulated to the Spring 2022 Regional Associations (NEWMA and CWMA). 

This new Form 15 adds a General Code requirement so that rather than revising a specific code in Handbook 

44 every time a new field or transfer standard is proposed or developed, an overall statement in the General 

Code recognizes the use of other field and transfer standards that meet the requirements for use as field or 

transfer standards. The proposal is as follows: 

G-N.3. Test Methods. – Permissible test methods for verifying compliance of weighing and measuring 

systems with the provisions of the General Code and Specific Codes include, but are not limited to, test 

methods and apparatus that have been approved by the State Director of weights and measures as outlined 

in Appendix A - Fundamental Considerations, Section 3. Testing Apparatus. 

NIST OWM also observed that the definitions in Block 8 should include appropriate references to the NIST 

HB 44 codes. 

OWM Recommendation: The submitters agree that these items, GEN-19.1 and OTH-22.1 are fully 

developed and requested that this S&T Committee consider that Block 8 item be a Voting Item in 2023.

Mr. Charlie Stutesman (Kansas) – GEN-19.1 line 29 – strike “as determined by the Director” “short term” 

and “extended term” are ambiguous phrases.
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Mr. Loren Minich (Kansas) – Page 277 line 41 regarding a Type 2 transfer standard not being stable or 

valid over extended time, but OTH-22.1 page 279 line 28 says the Type 2 standard must be stable and valid. 

Mr. Minich would like to keep as Developing.

Mr. Doug Musick (Kansas) - Page 277 definitions: having the 1/3 rule in the code (and not in an appendix) 

is helpful. Suggested that Type 2 should go away and just have a single “transfer standard” definition.

Mr. Michael Keilty (Endress+Hauser) – “Short term”, “extended period of time”, “short period of time”, 

“stable”, “valid” are arbitrary; who defines this? Who is going to establish this time period and 

qualifications of devices? Are we establishing a program for that? API chapter 4.8 dictates 5 year 

calibration intervals for small volume provers, for example.

The CWMA S&T Committee recommends this moves forward as a voting item.

(B8: OTH-22.1)

During the 2022 Annual Meeting Open Hearing Mr. Russ Vires (SMA) - Supports OTH-22.1 as 

Developing. Stakeholders need to review and provide input to the submitter.

The CWMA S&T Committee recommends this moves forward as a Voting item.

References: 

[1] 2022 - NIST OWM Analysis and Final reports https://www.nist.gov/pml/weights-andmeasures/publications/owm-technical-analysis

[2] 1905-2021 NCWM Annual Conference reports www.nist.gov/pml/weights-andmeasures/publications/ncwm-annual-reports

[3] National Conference on Weights and Measures (2022) Publication 15 and 16. 

https://www.ncwm.com

Appendix A: Supplemental Documents