Dear GMO,
Impressed that you are able to simplify these things so concisely.
The beloved rule initiators seem to be slightly less confident, eg -
9. The existing Regulations were made 20 years ago and are based upon legislation dating from 1979. Since then, technological changes and process innovation have resulted in significant improvements to weighing and measuring equipment. For example 20 years ago there was relatively little computer-controlled equipment, but today it is the norm, allowing for much greater standards of accuracy. Therefore, the list of suitable equipment prescribed in Schedule 4 is increasingly out of date. This may act as a barrier to the adoption of new technology by packers and as such a barrier to innovation.
10. The existing Regulations are complex and, although there is a more comprehensible code of practice for packers, it may be hard for some packers to understand the extent of the duties placed upon them. This level of complexity in the Regulations may also act as a barrier to entry for companies new to the market. The Better Regulation Task Force identified Part V of the Weights and Measures Act 1985 as unnecessarily burdensome and complex in their report into Consumer Affairs in May 1998. Both the Committee on Public Accounts and the National Audit Office recommended reform in their respective reports on weights and measures in 2003. The proposed changes will simplify the Regulations and remove unnecessary burdens from packers and importers.
(EXPLANATORY MEMORANDUM TO THE WEIGHTS AND MEASURES(PACKAGED GOODS) REGULATIONS 2006 No. 659 ) (24 Pages!!)
The original directives contained this –
1.2. the proportion of prepackages having a negative error greater than the
tolerable negative error laid down in 2.4 shall be sufficiently small for
batches of prepackages to satisfy the requirements of the tests specified
in Annex II;
1.3. no prepackage having a negative error greater than twice the tolerable
negative error given in the table in 2.4 may bear the EEC sign provided
for in 3.3.
I noticed a later interpretation as –
1.2 "the proportion of prepackages having a negative error greater than the tolerable
negative error laid down in 2.4 shall be sufficiently small for batches of prepackages
to satisfy the requirements of the tests specified in Annex II."
The ‘tolerable negative error’ for each nominal quantity is specified in paragraph 2.4 of
Annex 1 of the Directive. The quantity which is one tolerable negative error below the
nominal quantity is sometimes referred to as ‘TU1'.
A ‘defective prepackage’ is one whose contents is below TU1.
For these purposes ‘sufficiently small’ should be taken to mean that not more than 2.5% of the prepackages in the batch may be defective and the reference test in 2.3 of annex II is also satisfied.
NOTE: Reference tests are only for the Competent Department to use, they may not be
used by Packers or Importers to show compliance with the Directive.
1.3 "no package having a negative error greater than twice the tolerable negative error given in the table in 2.4 may bear the EEC sign provided for in 3.3"
The quantity which is two tolerable negative errors below the nominal quantity is sometimes referred to as ‘TU2'.
Solely for the purposes of setting up a quantity control system, it will be considered
acceptable if the probability of producing one prepackage below TU2 is not more than 1 in 10,000.
(Guidance for the Harmonised Implementation of Council Directive 76/211/EEC
WELMEC European cooperation in legal metrology, 2000)
(underlining is mine)
Personally, I liked to carry out some of the statistical tests included so as to be forewarned of what to expect from an official analyst. Of course, if all the packages always have net weights above the declared net weight, further evaluation is superfluous.
Rgds / Charles.C
