TC7/SC5 Working draft for Revision of OIML 129 - Participating country comments
TC 7/ SC 5 WD OIML R129 “Multi-dimensional measuring instruments”
Date of circulation:
TC 7/ SC 5 Secretariat: Australia
Comments due date:
Organization: National Measurement Institute (NMIA) Legal Metrology Policy
Contact Information: InternationalLegal@measurement.gov.au
Comments on:
No.
1
Country
Code
Page
Clause
Gen/Tech/Edit
Secretariat’s response
Comment
PL
UK
general
general
Poland has no comments regarding this document.
UK Supports this working draft.
Thank You for the feedback.
Thank You for the feedback.
NL
general
Lay out of the Recommendation is not in line with new (draft) template
http://workgroups.oiml.org/tcsc/general-templates.
Accepted.
4
NL
general
Accepted.
5
NL
general
In line with international accepted conventions the definition is to start
without capital and without an article. (It should be possible to replace
the term by it definition without any changes)
Please be aware of the developments regarding the new (almost
finished) VIML.
6
NL
general
VIM contents has completely changed
Accepted.
7
NL
edit
wrong symbol “ Ұ “ in use through the document
Accepted.
8
CA
6
2
tech
Accepted.
9
CA
6
2.1.1
general
The paragraph includes an outdated reference.
The reference should be changed to International Vocabulary of
Metrology – Basic and General Concepts and Associated Terms (VIM
OIML V 2-200 Edition 2012 (E/F).
To more precisely describe these instruments, Canada proposes the
following text.
A measuring instrument which measures the length (L), width (W) and
height (H) of an object a rectangular parallelepiped ( a rectangular box)
and in some instances cases determines the volume of that object. If the
object is not in the form of a rectangular shaped box, the dimensions
and/or volume of the smallest hexahedron rectangular box which fully
encloses the object is determined.
Change the word ‘size’ to ‘side’.
Accepted.
2
3
10
CA
7
2.1.1 (b)
edit
Accepted.
The current wording in the document refers to a ‘Rectangular Box (see clause
2.2.1) as a polyhedron. This includes within its scope a hexahedron.
Consequently suggestion to incorporate the term ‘hexahedron’ is not accepted.
Please note clause 2.1.1 has been amended to read, “A measuring instrument
which measures the length (L), width (W) and height (H) of an object and in
some instances determines the volume of that object.”
No.
Country
Code
Page
Clause
Gen/Tech/Edit
Comment
11
CA
7
2.2.1
general
Not accepted. See secretariat’s response for comment 9.
12
CA
8
2.2.2
general
Canada proposes deleting this section entirely and replacing it with the
following text.
2.2.1 Hexahedron
A geometric solid or box consisting of six rectangular planes.
Substitute the new term throughout the document as necessary. This
term is also the basis for the adjective, “hexahedronal”.
Replace “rectangular box” with “hexahedron”.
Any object other than a hexahedron rectangular box
13
CA
8
2.2.4
general
To coincide with the proposed change to section 2.2.1, Canada
proposes that this term also be changed and the definition amended.
Not accepted. See secretariat’s response for comment 9.
Secretariat’s response
Not accepted. See secretariat’s response for comment 9.
The term volume in some parts of R 129 has the typical meaning and in
some other parts has the defined meaning. In order to distinguish the
two, Canada proposes that the new term “hexahedronal volume” be
added throughout the document where applicable.
14
CA
8
2.2.6
general
To coincide with the proposed change to section 2.2.1, Canada
proposes that this term also be changed and the definition amended.
“2.2.6 Hexahedronal dimensions
The length (L), width (W) or height (H), measured by the instrument, of
the smallest hexahedron rectangular box which fully encloses the
object.”
The term “measured dimensions”, although defined, doesn’t occur in R
129. There are instances where the word “dimension(s) has been used
(with its normal meaning) and sometimes where the defined term
should have been used.
Canada proposes that the new term
“hexahedronal dimensions” be added throughout the document where
necessary.
Not accepted. See secretariat’s response for comment 9.
15
CA
8
2.2.8
general
In Canada, deeming a dimensional weight to be a weight value is
problematic. It’s also not seen as being necessary for the purposes of
this Recommendation. Canada’s proposal is to remove ‘deemed to be a
weight value’ from the definition and throughout the Recommendation.
Accepted.
The dimensions and volume being referred to in this section are those
of the smallest hexahedron which may or may not be the same as the
actual dimensions and volume of the object. This should be clarified in
the definition.
16
NL
9
2.2.10
edit
adaption of a VIM or VIML term is not accepted according to CIML
2011 Resolution 24.
Accepted.
17
NL
9
2.2.11
edit
addition “and software”.
Accepted.
No.
Country
Code
Page
Clause
Gen/Tech/Edit
Comment
18
CA
9
2.3.4
general
Correction of the VIM reference to that of the current VIM.
Suggest [adapted from VIM 4.26 5.24 ]
Accepted.
19
CA
9
2.3.7
general
Accepted.
20
CA
9
2.3.9
general
Correction of the VIM reference to that of the current VIM.
Suggest [VIM 2.52 2.7 ]
Correction of the VIM reference to that of the current VIM.
Suggest [adapted from VIM 4.11 5.7 ]
21
CA
10
4.1.1
tech
Canada does not support the proposal of changing the minimum
measurement from 10 d to 5 d when d ≤ 2 cm. Canada believes that this
change represents an excessive mpe when the mpe is a fixed value of ±
1 d.
Canada recommends that the minimum measurement when d ≤ 2 cm be
increased since even 10 d represents an excessive mpe.
In Table 1
d ≤ 2 cm
12 d
Accepted.
The amendment to minimum dimension for scale interval d ≤ 2 cm has been
reverted back to 10d.
To incorporate comments from Japan and UK, the following words have been
added as a note to clause 4.1.1:
“Note: However if a manufacture can meet a lower minimum dimension
criteria, then it can be specified according to clause 5.3.1.”
The revised wording will not restrict the use of this document to current
technology.
22
FR
10
4.1.1
tech
We are not in favour of the decrease of the minimum dimension from
10d to 5d, for the scale interval d< 2 cm.
We don’t understand the interest of this decrease since at this minimum
dimension (5d), the measuring result of each dimension of a very small
object will be subject to an excessive admitted error (20 % of 5d) . This
is not coherent with the definition of min and with the policy applied in
other categories.
Keep the minimum dimension 10 d.
23
NL
10
4.1.1
tech
Amendment of Minimum dimension (min) (lower limit) from 10 d to 5
d now deviates from the EU MID MI-009 requirement.
http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:135:0001:00
80:EN:PDF
(page 77; table 1)
Revert amendment to keep harmonized.
24
UK
10
4.1.1
tech
Japan previously raised the following comment.
“In the future revisions of R129, we request the minimum dimension
would be decreased from 10d to 5d (d=scale interval). It is because a
measurement of small thickness is important in Japan for the envelopes
treated at postal offices and/or delivery service stations.” which has
been accepted in this WD.
The UK supports this change. The previous minimum dimension of 10d
aligned to current technology limitations mean that UK postal services
are not collecting the measurements of a number of thin items. The
change to 5d is acceptable even though it means errors of 20% are
permissible for d < 2 cm which we believe is reasonable for small
measurements with current technology.
Secretariat’s response
Accepted.
No.
Country
Code
Page
Clause
Gen/Tech/Edit
Comment
25
NL
11
4.1.3
edit
Not accepted.
The word “indicator” is defined in clause 2.1.5.
26
CA
11
4.1.6 (a)
general
27
DK
12
4.1.6(a)
tech
28
NL
11
4.1.6 (a)
general
29
NL
12
4.1.6 (a)
edit
There is no variation allowed so it is a bit strange to use the wording
“maximum permissible variation” Moreover “indicator” is not defined.
Suggest changing “indicator” to “indicating device” and amending
heading to read “Difference between indications (of indicating
devices)”.
To clarify the intent, add the word “hexahedronal”.
(a) When a test is conducted, the expanded uncertainty (coverage factor
k = 2) of the determination of the errors on indications of hexahedronal
dimensions shall not be greater than one-third of the mpe specified (see
GUM).
The International Recommendation OIML R 129 on Multi-dimensional
measuring instruments has a clear inconsistency with the consequence
that it is impossible to meet the requirements of the recommendation
for instruments without a device for displaying the indication with a
smaller scale interval. The requirement in 4.6 (a) that uncertainty of
error in the indications of measurement, U ≤ d/3, can never be met
unless the instrument has a device for displaying the indication with a
smaller scale interval (better resolution).
This issue could be resolved in the following ways:
1) OIML R129 could be rewritten so that it only gives
requirements on the uncertainty of the size of the test objects.
This would be in line with e.g. OIML recommendations for
weighing instruments.
The requirement could be relaxed to “...the errors on indications of
dimensions shall not be greater than two-third of the mpe specified (see
GUM)”.
When applying the suggested subdivision: performance requirements,
test method and test report respectively for the 3 parts of the
recommendation 4.1.6 (a) should be located in Part 2.
Suggest shifting 4.1.6 (a) to Part 2.
k = 2: coverage factor k should be in italics.
Suggest amending according to guide OIML G 1-100 (= OIML version
of the GUM) http://www.oiml.org/publications/V/V002-200-e12.pdf.
30
NL
11
4.2.1
general
Rated Operating Conditions are not specific for influence factors.
Humidity generally is considered an influence quantity.
(See OIML D11)
They are to be taken into account during influence factor testing.
Delete “for influence factors”.
Accepted.
Secretariat’s response
Not accepted. See secretariat’s response for comment 9.
No change.
Please see secretariat’s note at the end of clause 4.1.6(a).
No change.
Document has been restructured in line with the new template (see comment
3). Consequently, the clause 4.1.6 falls under Part II, Metrological and
Technical Requirements.
Accepted.
No.
Country
Code
Page
Clause
Gen/Tech/Edit
Comment
31
NL
11
4.2.1
general
The general principle is that a requirement is formulated such that the
instrument is not allowed to exceed the limits specified when exposed
to the applicable conditions. A test is merely the verification on a
specific moment that the instrument performs as required and may be
limited to specific measurement points expected to be critical.
Therefore the formulation in the requirement should not restrict to (or
mention) the testing.
Suggested amendment:
Instruments shall be designed and manufactured such that they do not
exceed the mpes when exposed to tested over the following ranges of
influence factors environmental conditions:
Delete one of the 15 % entries.
Secretariat’s response
Accepted.
32
Canada
11
4.2.1 (a)
edit
Accepted.
33
Canada
11
4.2.1 (last
sentence)
edit
The reference in the last sentence should be changed to 30 degrees
Celsius.
Accepted.
34
NL
11
4.2.2
general
35
NL
12
4.3.1,
4.3.2
edit
No change.
The suggested change has been implemented for clause 4.2.1. Therefore no
change to avoid duplication.
Accepted.
The current headings have been revised as follows to reduce ambiguity in the
meaning:

‘4.3.1 Disturbance applied to measuring instrument.’

‘4.3.2 Disturbance applied to devices.’
36
NL
12
4.3.3
edit
See 4.2.1
State the condition (humidity + temperature) and use similar
formulation as suggested for 4.2.1.
headings sound a bit weird.
4.3.1 concerns reaction when exposed to disturbances, and 4.3.2.
A note should not contain a requirement. In fact in 4.3.1 the note
contains the actual requirement.
There is no need to limit the requirement to electronic instruments.
Suggested changes:
Response when exposed to disturbances applied to instrument
An electronic The instrument shall be designed and manufactured such
that, when exposed to disturbances, either:
(a)
significant faults do not occur; or
(b)
significant faults are detected and acted upon.
Note:
A fault equal to, or smaller than, d is allowed during the
disturbance irrespective of the value of the error of indication prior to
the disturbance.
5.3.2
Disturbance applied separately Effect of multiple faults
The requirement in 4.3.1 may be applied separately:
(a)
to each individual cause of significant fault; and/or
(b)
to each part of the electronic instrument.
The choice whether (a) or (b) is applied is left to the manufacturer.
This sub clause is a combination of a performance requirement and the
test requirements.
Suggest changing to,” Instruments shall be tested as to withstand the
disturbances expected to be exposed to during operation.”for the
appropriate disturbances as listed in Table A.1. The severity levels of
the disturbances are given in A.3
Accepted.
The document has been amended to read, “Instruments shall be tested as to
withstand the appropriate disturbances as listed in table A.1”.
No.
Country
Code
Page
Clause
Gen/Tech/Edit
Comment
37
CA
12
4.3.5
general
To clarify the intent, add the word “hexahedronal”.
Suggest, “If in normal operation the instrument indicates the
hexahedronal volume and not the hexahedronal dimensions, a test mode
shall be provided to display or print out the hexahedronal dimensions”.
Not accepted. See secretariat’s response for comment 9.
38
NL
12
4.3.5
edit
Accepted.
39
NL
13
5.1.4
edit
concerns testing
...pattern of an instrument.. (“pattern” = depreciated).
Suggest to shift to part 2
..type of instrument..
“ready” weird use of language. Could mean either finished or prepared
for measurement.
Suggest “prepared for use” and restrict the title to “adjustments”
40
NL
13
5.2
edit
Indicator is not defined.
Indicator is defined in clause 2.1.5.
41
CA
14
5.2.5
tech
Fixed zeros to the right of the decimal point give the impression of a
greater degree of precision than exists. Canada recommends that the
text be replaced.
All decades to the right of the decimal point or comma must be active.
42
CA
15
5.2.9.2 (a)
general
Replace “rectangular box” with “hexahedron”.
Accepted.
Following text has been added to clause 5.2.5:
“Please note that all the decades to the right of the decimal point or comma
must be active and the least significant digit should correspond to the scale
interval”.
Not accepted. See secretariat’s response for comment 9.
43
CA
16
5.2.9.1 (a)
edit
To clarify the intent, add the word “hexahedronal”.
Not accepted. See secretariat’s response for comment 9.
44
CA
16
5.2.9.1 (b)
edit
To clarify the intent, add the word “hexahedronal”.
Not accepted. See secretariat’s response for comment 9.
45
CA
16
5.2.9.1 (d)
tech
Not accepted.
Clause 5.2.9.2 (b) clarifies that dimensional weight is a calculated weight and
not actual weight.
46
CA
16
5.2.9.1 (e)
tech
To more clearly emphasize that dimensional weight is a calculated
value and not an actual weight, Canada recommends that the example
be changed. Dimensional weight can be expressed with no unit (i.e.,
dim xx) or when a unit is used, the DW identifier should be placed
between the numeric value and the unit symbol (i.e., xx dim kg).
The use of tare is not in fact ‘dimensional’, it’s an actual length. To
clarify this, the term “dimensional” should be deleted and replaced with
the word “linear”. The symbol should also be changed.
The example of dimensional tare includes the symbol kg. However,
since the tare is for linear units, kg is inappropriate.
Canada recommends that the example be changed to simply (LT); or
(LT…mm, LT…cm, or LT…m);
To clarify the intent, add the word “hexahedronal”.
Remove the phrase “deemed to be a weight value” and to emphasize
that the quantities are those of the theoretical box and may not be those
of the object, add the word “hexahedronal”.
It’s not clear why this restriction should be added to the nameplate
when it is already addressed in 5.3.2 (e). It’s also not clear that this
particular restriction is of greater significance than the other restrictions
in 5.3.2.
The phrase “deemed to be a weight value” has been removed.
Please see response for comment 9 regarding the word ‘hexahedronal’.
47
CA
15
5.2.9.1(g)
general
48
CA
15
5.2.9.2 (b)
general
49
CA
17
5.3.1 (i)
edit
Secretariat’s response
Not accepted.
The word ‘Ready’ is used in the heading, as some of the multidimensional
instruments display ‘ready’ instead of zero ‘0’. The current wording enables
instruments that can meet either ‘zero’ or ‘ready’ requirement.
Accepted.
Text has been amended to read, “e. dimensional tare (DT ... kg) or linear tare
(LT…..cm);”
Not accepted. See secretariat’s response for comment 9.
Accepted.
No.
Country
Code
Page
Clause
Gen/Tech/Edit
50
CA
16
5.3.2 (f)
general
Replace “rectangular box” with “hexahedron”.
Not accepted. See secretariat’s response for comment 9.
51
CA
16
5.3.2 (g)
general
Remove the phrase “deemed to be a weight value” and to emphasize
that the quantities are those of the theoretical box and may not be those
of the object, add the word “hexahedronal”.
The phrase ‘deemed to be a weight value’ has been removed.
“10.1
General
Electronic measuring instruments shall be constructed so that they
comply with the following metrological and technical requirements.
10.1.1 Influence factors
Influence factors specified in clause 5 and corresponding test
procedures specified in Annex A.
10.1.2 Disturbances
Disturbances specified in clause 5 and corresponding test procedures
specified in Annex A.”
Accepted.
Document has been rearranged and updated as follows:
‘5.5 Instrument Construction
with 5.5.1 General and
5.5.2 Auxiliary devices requirement
and
5.6 Checking Facilities
with 5.6.1 Acting upon significant faults and
5.6.2 Indication Check.’
Original clauses 5.5.2 and 5.5.3 have been removed from the document.
52
NL
17
5.5.1,
5.5.2
5.5.3
5.5.4
5.5.5 &
5.5.6
general
Secretariat’s response
Comment
53
NL
19
6
edit
Not correctly formulated while influence factors and disturbances do
not specify requirements, but specify conditions.
The clause should describe that when the instrument is being exposed
to influence factors as specified in clause 5 the error (of indication)
should stay within the mpe. And further when being exposed to the
specified disturbances that no significant fault should occur. Reference
to the tests is not necessary while the testing does not concern the
performance requirements but concerns the procedure to be applied on
a specimen to verify that the performance criteria are met.
In the testing part reference may be made to the specific performance
requirements in part 1, of which the verification is considered being
covered by that test.
Pattern approval (depreciated). Replace by “Type evaluation”.
54
FR
19
6.1.4.2
edit
“N ◊ d” needs to be corrected with “N x d”
Please see response for comment 9 regarding the word ‘hexahedronal’.
Accepted.
Accepted.
“5 Ұ 10n” needs to be corrected with “5 x 10n”
55
FR
20
6.1.4.3
edit
56
CA
19
6.1.4.5
general
“N ◊ d” needs to be corrected with “N x d”
Accepted.
To clarify the intent, add the word “hexahedronal” and replace
“rectangular box” with “hexahedron”.
Not accepted. See secretariat’s response for comment 9.
No.
Country
Code
57
NL
58
NL
Page
Clause
Gen/Tech/Edit
Comment
Secretariat’s response
Annex A
general
Many referenced documents have been updated.
For harmonisation it is suggested to use the OIML D11 suggested layout (tables) If so decided the OIML TC 5/SC 1 secretariat offers to
deliver this tabulated input.
Apply OIML D11 + OIML E5 to update the tests
http://www.oiml.org/publications/D/D011-e04.pdf
and
http://www.oiml.org/publications/E/E005-e12.pdf
and approved 2CD OIML D11
http://workgroups.oiml.org/tcsc/tc-05/tc-05-sc-01/project-p1-revisionof-oiml-d11/2-cd-v-oimld11/TC_5SC_1_0016_2CDV%20OIML%20D11%20clean.pdf/view
Accepted.
The layout suggested in the draft OIML D11 (2013) document has been
implemented.
general
It should be decided whether extension of performance test is required.
E.g. decide on applicability of:
Accepted.
Surge tests have been added at clause A.3.4, consistent with the draft OIML
D11 (2013) document.
surge tests (when long cabling is connected .e.g.)
-
tests on data lines
tests for vehicle installed instruments
conducted (common mode currents) below 30 MHz
See OIML D11.
No.
Country
Code
Page
Clause
Gen/Tech/Edit
Comment
Secretariat’s response
60
NL
28
A.3.5
tech
The description of methods of exposure origins from standards from
about 30 years ago. Please copy the applicable part of OIML D11 (and
suggested of the 2CD OIML D11, while this document is already
approved for the approval phase).
Only the underneath paragraphs still are applicable and may stay part of
the clause.
Accepted.
The test procedures have been revised to be consistent with the draft OIML
D11 (2013) document.
Test procedure in brief
The EUT shall be exposed to electromagnetic radiation under constant
environmental conditions. The field strength can be generated using the
following methods:
---------When the test is carried out in a shielded enclosure to comply with
international laws prohibiting interference to radio communications, the
effect of reflected radiation from the shield shall be negated by such
means as anechoic shielding.
Test level
The EUT shall be tested as specified in A.1.2 at a field strength of 10
V/m, 80 % AM, 1 kHz sine wave modulated over frequency ranges of
26 MHz to 2 000 MHz for EUT having no mains or other input port
available and 80 MHz to 2 000 MHz for EUT having mains or other
input port available.
Maximum allowable variations
If the instrument does not detect and react to a significant fault
occurring as a consequence of the electromagnetic susceptibility of the
instrument, then the fault shall not exceed the value defined in 2.28.
References
lEC 61000-4-3 and IEC 61000-4-20
In the first sentence, replace “rectangular box” with “hexahedron”.
Not accepted. See secretariat’s response for comment 9.
61
CA
32
Annex B
B.1
general
62
CA
33
Annex B
B.2
general
Replace “rectangular box” with “hexahedron” and make some editorial
changes to the text.
Not accepted. See secretariat’s response for comment 9.
63
CA
34
Annex B
B 3.9
general
In the first sentence of the second paragraph, replace “rectangular box”
with “hexahedron”.
Not accepted. See secretariat’s response for comment 9.
64
FR
36
edit
In the title please read report (with a t at the end)
Not accepted. See secretariat’s response for comment 9.
65
FR
53
Test
report 6
edit
“sec” is not correct
Accepted.
66
FR
56
Test
report 8.1
edit
“sec” is not correct
Accepted.