NIST Laboratory Metrology: Previous Comments on Draft HB

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Previous Comments on Draft HB

Section	ID	Date	Draft Number	Source	Recommendation	Comment	Proposed	NIST Response
	221	9/6/2001	2	SC	n	Fill fuel tank for user due to percentages of error/tolerances.
1.1
	53	6/1/1999	1	L.F. Eason (NC)	Yes	Confusing – this section states that weight carts are “NOT to be considered Class F Field Standards”. Yet the document title is NIST Handbook 105-1, Appendix I, Field Standard Weight Carts”. I still favor this being a separate 105 series document so tha	Separate Handbook from 105-1.
	108	3/18/1999	1	Jim Price (MD)	Yes	Section 1.1 appears to conflict with Section 9.1	Section 1.1 Field Standard Classification. These specifications are limited to motorized weight carts used in conjunction with Class F test weights. The specifications permit the use of a weight cart at its nominal value where the tolerance on the devic
	120	1/13/1999	1	Craig Olsen (NE)	No	According to this section, weight carts should not be used to test scales. I am confused by the contradictory statements of this draft. Under the heading in the "historical policy and practice" in the background information, it is stated that these cart
	136	6/26/1998	0	Jerry Clingaman (IN)	No	8. It should be noted that approval and/or calibration of carts is done with the understanding that carts do not meet NIST specifications for test weights and the above restrictions are designed to keep cart within 1/3 of a scale with 10 lb divisions. (
	163	9/5/2001	2	EH	NO	Comment: clarification of Class F and field standards.
1.2
	14	6/15/1999	1	Jim Brown (MI)	No	As long as our cart stays in tolerance, we will be allowed to use with only two axles. When our cart was calibrated last April it was heavy from the last time it was calibrated.
	19	5/17/1999	1	WRAP	No	Use if you have a history - what about carts that are not ok in terms of specifications, ok in terms of tolerance at the moment you test them, are in use, but don't have a history? Do we have to throw them out? Should we allow a period for the history t
	40	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	As carts were not to be used, but some States proceeded to use we do not see any reason for limiting use due to not maintenance tolerances between tests. They have been acceptable up to this point. Do not change the rules and penalize industry.
	155	6/23/1999	1	G. Harris (NIST)	No	Nothing in this handbook "bans" weight carts that are already in place. Retroactivity clauses were included to allow continued use of those weight carts which have maintained tolerances between verification tests. Any weight carts that do no maintain ad
	164	9/5/2001	2	BA	Yes	We need to define "time of placing in service"; e.g. if it's manufactured already and sitting on the lot but not in service yet.	Placed in service, manufactured after x/x/y date.	ID Plate indicates date of mfg.
	165	9/5/2001	2	LFE	Yes	Would like to see the date pushed out further also.	Suggest 10 years.	Depends on which aspects require retroactivity.
1.3
	36	6/1/1999	1	Tom Schafer (ID)	Yes	Editorial.	The use of weight carts "may" require the handling of petroleum products.
	166	9/5/2001	2	LFE	Yes	Seems like the obvious one: that we are dealing with large weights.	Add "large weights"	OK
	167	9/5/2001	2	BA	No	This is not the document where we need to deal with additional features on safety.
	168	9/5/2001	2	EH	no	Don't drive the cart inside the laboratory. (In the SOP). Driving a gas powered cart in the lab.
	169	9/5/2001	2	LFE	yes	Carbon monoxide exposure in enclosed spaces.	Add "carbon monoxide if used in enclosed spaces"
1.4
	170	9/5/2001	2	VM	no	Question: how many are metric out there? Many have the capability but are not used in that capacity.
	171	9/5/2001	2	EH	no	Why specify a 60 F? Reference for petroleum products and reference weights.
2
	172	9/5/2001	2	LF	Yes	Other 105's?	Add 105-1; carts are used in conjunction with Class F field standard weights. Publication 3 reference will be contradictory when the carts documents are done. Pub 12 will be HB 112 and moved.	Discussion at the regional W&M meetings to deal with Pub 3?
3
	173	9/5/2001	2	VM	Yes	Add field standard definition.	Pull from other 105.	OK
	174	9/5/2001	2	LFE	no	Do we need to define any weight cart parts? Hydraulic drive? Axle?	not yet
	175	9/5/2001	2	EH	No	We are really not interested in axles - but in contact points and a definition may clarify that.	Nothing yet.
	176	9/5/2001	2	BA	Yes	Terminology - global, large concept type terminology. It's probably best to leave definitions for axles where they are.	Leave where they are.
4.1
	41	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	Of what value is this? Restricts design/building of carts. Make it. Mark it. Use it.
	74	6/1/1999	1	Bill West (OH)	Yes	I think we should allow 100 lb increments. 500 lb increments may cause a lot of welding and cutting on carts after a few years and a few modifications.	Allow 100 lb increments.
	81	1/1/1999	1	Sid Colbrook (IL)	Yes	Because a 5 000 lb cart is a common size and is referenced in the draft, we would recommend it be added to the "such as" sizes.	See comments.
	89	6/1/1999	1	Mike Dynia (CT)	Yes	Minimal value of cart: 3 000 lb.	Minimum value proposed.
	100	6/1/1999	1	Brenda Whitener/Jens Paulsen (GA)	Yes	We have received a new cart that weights 3 008 lb and the adjustment cavity (see section 4.3.8.1) was empty and downward adjustment to the desired 3 000 lb weight was impossible.	Add: The mass weight of the cart should be just below the intended weight to allow room for up and down adjustments.
	133	6/26/1998	0	Jerry Clingaman (IN)	No	5. Carts will be calibrated to even 100 lb whenever possible. (lab admin procedure # 15.6)
	138	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: availability of working standards with appropriate and sufficient uncertainties for substitution weighing.
4.1.1
	1	6/15/1999	1	Weight Carts, Inc	Yes	It would be beneficial to all weight cart sales if it were known, before a sale of a weight cart, what these restrictions in any jurisdiction would be. In our opinion, there should be no size restricting based upon the size of test weights. Some states	Supply testing methods and limitations of all approved testing entities.
	2	6/15/1999	1	Weight Carts, Inc.	Yes	If the weight cart any any combination of test weights are within tolerance there is no need to specify multiples to be used for loading carts.	A weight cart may be used with any combnation of test weights as long as it maintains acceptable tolerances.
	20	5/17/1999	1	WRAP	No	(see also 9.1) (CA]. This is unclear. Mass of 4 times the weight of the cart. We need to clarify the intent. The number of weights should be a function of the uncertainty related to the number of weights. The division would have to know work load an
	32	6/1/1999	1	ID	Yes	Generator powered carts can meet uncertainty requirements and should be able to be used alone.	Eliminate load requirements for generator powered carts.
	37	6/1/1999	1	Tom Schafer (ID)	No	2nd sentence - not so.
	42	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	Again, this limits/restrains manufacturing/design.
	54	6/1/1999	1	L.F. Eason (NC)	Yes	Don't understand last sentence. Suggest striking it completely.	Strike last sentence.
	75	6/1/1999	1	Bill West (OH)	No	If we state that a weight cart must be used with at least 4 times capacity, we will prohibit testing a scale at the lower weights. (A 4 000 lb cart could not be used to test at 10 000 lb).
	82	1/1/1999	1	Sid Colbrook (IL)	Yes	A clarification is needed. Can a 5 000 lb cart be used to test and record values less than 20 000 lb? If not, then a severe restriction is placed on the use of motorized weight carts. If weight readings cannot be taken below four times the weight of th	Eliminate Section 4.1.1.
	106	6/1/1999	1	Mike Kramer (VA)	No	A mention of the center of gravity. We test them from a hanging load cell, in which the center of gravity comes into play.
	124	6/22/1999	1	G. Harris (NIST)	No	The practice of using weight carts as "Class F Field Standard Test Weights" leads the way for inappropriately using fully loaded trucks as standards as well (which is already being done in some jurisdictions). The variability observed in data for the var
	125	6/24/1998	0	Vic Gerber (WY)	No	NIST HB 44 - Fundamental Considerations, permits a field test weight to meet Class F or 1/3 of the smallest tolerance to be applied in the field. Very rarely do I represent a motorized vehicle (except railroad test cars) as meeting or maintaining Class F
	139	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: a local jurisdiction must be able to test standards or accept certificates through reciprocity from another laboratory able to test and use the weight cart. An untested standard is generally not legal to use in testing devices. Peo
	156	9/5/2001	2			No comments.
	161	9/5/2001	2	EH	Yes	Uncertainty in calibrations; evaluate it in the calibration to determine if it is acceptable. LAC has 100 lb standards in the lab.	"if they hold their tolerance"; perhaps have a grace period.
	177	9/5/2001	2	BA	Yes	Needs a larger window than 20 to 50 lb.	Maybe suggest 50 to 100 lb instead of 20 lb and 50 lb. Maybe have multiple adjustment cavities. Maybe a percentage size of the cart or the value of a scale division on the cart. (e.g., -50 to + 75 lb)?	Why some are dealing with odd sized carts (e.g., 4100 lb carts). 4 batteries could have 8 to 15 lb differences each. 200 lb capacity cavity will get large. Cavities are sometimes adjusted to the size of the cart (JD). 4 x 6 tubing x 18" long is genera
	178	9/5/2001	2	EH	Yes	Split the 3 topics in 4.1.1.	Split the sections.	ok
	179	9/5/2001	2	EH	NO	Nominal: What would be the impediment to going in 500 lb increments?		JD: NO problem. Vary the top plate on the cart.
	180	9/5/2001	2	EH	No	Adjusting cavity should be sealable and fixed to the cart.	It is in 4.17
	181	9/5/2001	2	BA	no	Preference would be against welding a cavity in place.		agreed.
	182	9/5/2001	2	SC	Maybe	What if you have an adjustment cavity of 200 lb?	Specify that the adjustment is a minimum somehow.
	183	9/5/2001	2	EH	no	Does lead have any new restrictions?		Nothing new for shot. Problems with melting and waste materials.
	184	9/5/2001	2	LFE	No	Should be limited to shot for current cavity design.	No	Concern about being able to adjust. Cavity design limits whether shot is needed or not.
4.1.1.
	159	9/5/2001	2	BA	NO	Like having nominal weights, especially from perspective of laboratory testing. (VM: This is one of the reasons this was considered.) Calibration practices and available standards will affect nominal values.		IL: had a 3100 lb cart. Industry owns it now. Would suggest it be kept a non retroactive requirement.
4.1.2
	185	9/5/2001	2	GH	Yes	Background concern is having a capable laboratory to provide a calibration before purchasing a cart.	Leave statements in. Change "required" to "essential".	Good to note. SC: Let the buyer go to another state if they get it. LF agreed. GH: Could change "required" to "essential" in the last sentence. EH: people need to have the communications.
4.1
	213	9/5/2001	2					No comments? JD will check on it. (No grease zerks).
4.11
	214	9/5/2001	2			Additional work needs to be done on this section.
4.11.2
	215	9/5/2001	2	EH	Y		Should say "without treads".	(without treads). Some 2000/3000 lb have treaded tires. Used on portable vehicle installations and livestock scales. Have to have treaded tires to get on livestock scales. IL has a weight mover that is calibrated like a cart (with a motor).
4.12
	216	9/5/2001	2			LF: concern about a very long wheel base		LF - saying a tandem axle truck vs the wheel base and track. Can't really use a tandem. Val thinking track. Or should a typical dimensional range be included (4 to 8 ft?). BA: Unless there is some rationale, would prefer not to see the last sentence.
4.13
	217	9/5/2001	2					No comments.
4.14
	218	9/5/2001	2			Weight restraint.		No comments.
4.15
	219	9/5/2001	2				USE: Weight cart must be dry prior to use. No visible moisture. Suitable precautions must be taken to protect cart from water, snow, or environmental contaminations. Delete all except the last sentence in this section.	Open trucks - challenge in court? "to prevent contamination" clause. Can easily get 4 lb of water contamination on a cart.
4.16.1
	222	9/6/2001	2	GH	Y	Should it have "safely" included.	delete "safely"	SC: good to have it there; but if we allow it to go out and it wasn't quite level, is there a liability? GH: good engineering practices would ensure "safe" lifting mechanisms. BA: devices used for lifting weight carts, where you could literally have a
4.16.2
	223	9/6/2001	2	EH	Y	Should be "horizontal" position vs "level" position.	Change "level" to "horizontal"	BA: "approximately level". Approximately is a weasel word to allow some offset from a perfect level condition.
	224	9/6/2001	2	BA	Y	suggest changing title from "mechanism" to something like lifting "points"	change "mechanism" to "attach points"	LF: Do we want something about the "bar" if it is provided? GH: "by a means prescribed by the mfg" is in the original and should go in 4.16.1. LF: possibly divide into 3 section: means/method of lifting as prescribed by mfg; lifting points; balancing
4.16.3
	225	9/6/2001	2	GH	Y	revise entire 4.16 section to deal with attachment points; crane scale testing is part of the scope	Delete 4.16.3.1 and 4.16.3.2	BA: take out 4.16.3.1 and 4.16.3.2 because it shouldn't be done. DE: as a general practice, they don't test crane scales this way. GH: The lifting attachments for lifting the entire gross weight is unsafe. JD: "get 30 ft long 4" straps rated for th
4.17
	238	9/6/2001	2			and 4.1.1		105-1. Adjustment cavity must be at least 5 times the tolerance. Could set the adjustment cavity be based on a percentage of tolerance or nominal.
4.17.1
	226	9/6/2001	2	DE	Y	Why have lead or steel shot in the capacity.	Delete "of lead or steel shot"	4.17.3 deals with this.
	227	9/6/2001	2	JD	Y	Should it address multiple cavities (that may be used).	change "permanently attached"	VM/BA: We don't want someone welding the cavity to the cart. LF: Attachment of the cavity is really another section rather than "capacity". Should it specify more than one cavity? Does each cavity need to hold 100 lb of shot. DE: a weight cart cavi
	228	9/6/2001	2	EH	N	Express the weight cart capacity in gross weight - express the cavity size as a percentage (the way it is done in 105-1).		LF: nominal weight of the cart. Express the cavity size as a percentage as a nominal weight? JD: try to use the same parts on all carts and adjust body to adjust weights. Try to have parts uniformity. VM: add another section to deal with an auxiliary
4.17.2
	229	9/6/2001	2	VM	Y	Needs to be the "main adjustment cavity" or adjust both?	"all (or each) adjustment cavity openings" (vs "the")	LF: can stay generic and have both openings for the main cavity and an auxiliary cavity. Should each cavity have a single opening? BA: In most cases, there won't be extra/multiple cavity openings. But, don't see a problem with it. Preference for "ea
	232	9/6/2001	2	LF			Change "or" to "and"	Insertion and removal (vs or).
4.17.3
	230	9/6/2001	2					BA: for uniformity - remove bar stock in one place? It was left in. Ensure consistency - took "bar" out of 4.1.1. ? (NO it was left in.)
4.18
	233	9/6/2001	2			Do we need to require "brakes"? Automated brake?		BA: automated brakes - electronically actuated is a parking brake. Service brake implies operator controlled. Clearly cases where a device would have both brakes; others might have a combination.
	236	9/6/2001	2			General discussion of braking systems.		EH: suggest having a simpler approach with one paragraph. BA: should not preclude an additional parking brake (or braking system).
4.18.1
	231	9/6/2001	2	GH	Y	"will"	Change "will" to "shall" or "must" in the last sentence.
	234	9/6/2001	2	GH	y		Change "allowing the operator to" to "that allows the operator to"
4.18.2
	235	9/6/2001	2	BA	Y	Change to allow automatic braking	change "and" to "or" the operator
4.19
	237	9/6/2001	2	LF	Y	Reverse two sentences. Paint should be secondary to construction.	Revserse sentences.	SC: Does it really need to be painted? What about the rhino-liner suggested 9/5/01? Epoxy coatings are specifically not allowed on weights. Surface of the weights? Is it hygroscopic? It is touted as being a rust-preventative. (105-3 discussions of
	239	9/6/2001	2		Y		insert as done in 105-1 (see discussion).	Wording in 105-1 - insert susceptible to corrosion or tarnishing or oxidation shall have a protective surface coating. If paint or other surface protectant material is used it shall be hard and resistant to chipping. (Powder coating, baked coating, spray
4.2
	3	6/15/1999	1	Weight Carts, Inc.	Yes	There is no need to limit the fabrication of weight carts to steel only. Other materials could be used as long as the tolerances are maintained.	A weight cart may be fabricated from any material as long as their weight can be maintained and not be affected by temperature, weather, or other conditions.
	43	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	What if we can build a better cost with "composite" materials?
	140	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: durability, strength/support, density/buoyancy, corrosion resistance.
	186	9/5/2001	2	VM	yes	Question that was raised: can we use a strong polymer? SC: "similar, durable material"; LFE: "corrosion resistant" (Refers to weight cart body). SC: using an AL product on retail motor fuels systems. SC: sprayed weight carts and bases of weights:	Allow for possible new products coming along that may not be "steel". Nothing specific. Perhaps "such as steel". Similar properties.
	187	9/5/2001	2	GH	Yes	Swap 2nd and 3rd sentence.	Change 2nd and 3rd sentence order.
	188	9/5/2001	2	VM	Yes	Need to prevent rubber pads on the deck. Hygroscopic surfaces. Surface coating. LF: suggest adding a sections on surface finish; frame; flexible connectors.	Add sections for surface finish, frame, flexible connectors.	Some of the engines have plastic shrouding too.
4.2
	240	9/6/2001	2				substitute "cleaning" for "maintenance"?	Battery discussion: DE: left the word "seal" out. (Will be a retroactive requirement). Electric powered carts - do they have sealed, lead-acid batteries? (BA to check on electric cart battery requirements). EH: sealed and lead, use of words. Two se
	241	9/6/2001	2	JD		Batteries can be serialized.		To indicate changes, serial number can be included on battery. LF: good idea to brand the batteries. SC: a good idea to have the equipment in the lab and track on the checklist. LF/VM: don't mark on the posts. JD: an engraver can be used. Battery
4.21
	242	9/6/2001	2	LF				LF: enforceability question; it's a mfg question. VM: talking to mfgs, they are regulated
4.22
	243	9/6/2001	2		Y		All lubrication points must be accessible (period).	Pivot points will be lubricated. Steering assemblies. (Not bearings). VM: doesn't change mass. If excess grease is wiped off. EH: displaced old grease should be wiped off. LF/GH: design shall allow the removal of excess lubricants after servicing.
4.23
	244	9/6/2001	2	DE	Y	concern with "intrinsically safe". Doesn't believe that a cart out there is intrinsically safe. (Controlled, explosion proof area is the meaning of the terminology).	UL approved connectors. Take out "local" and leave electrical code. End middle sentence with electrical code. Move last sentence in first P to second P.	Will probably not be able to take any weight cart into an instrinsically safe area. Places where you can't refuel as well. Not allowed to make or break a connection on an electric cart, or take any kind of cart into an intrinsically safe area. Can't ope
	245	9/6/2001	2	GH	Y	delete use of word "certified" twice.	delete word "certified" in favor of "calibrated".
4.24
	246	9/6/2001	2		Y		Change to "may require". Change to two sentences instead of using semi-colon.	LF: Add "when" or "if" to the beginning of the sentence. Or "may require". Change to two sentences instead of using semi-colon.
4.3
	189	9/5/2001	2	VM	Yes	How far should we go with presenting design ideas?	Needs to deal with deviations from this specifications (GH). Suggest diagrams have a block diagram approach. (EH). Tiffin has material available on a computer too. (JD)	Suggestions for block diagrams. Include "representative" examples from manufacturers. Include engine, battery, umbilical cord (generator) operation samples.
4.3.1
	4	6/15/1999	1	Weight Carts, Inc.	Yes	Approval of design by local Weights and Measures Officials would be a waste of time by W&M officials and the manufacturers because the manufacturer knows the design. If any local weights and measures officials would like something added or changed for th	Prior to the sale of a weight cart, the customer is to be made aware that their local weights and meausres officials may be limited in the ability to do regular calibration of a weight cart.
	44	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	If approved by ODA (OH Dept of Ag), does that mean ODA would be a party to any lawsuits resulting from "who knows what?"
	141	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: primary design concerns have to do with State expectations for how scales are to be tested as well as laboratory testing capabilities.
4.3.10
	8	6/15/1999	1	Weight Carts, Inc.	Yes	This section deals with brakes so I feel that brakes should be mentioned for while the cart is being used, not only when dismounting. The method in which our carts are used we would not want this to automaticaly engage. We have service brakes for smooth	All weight carts shall be designed with service brakes to be used while the operator is using a cart and a parking brake to be applied when the cart is not in use.
	39	6/1/1999	1	Ken Johnson (OH)	No	Design and cost factor for manufacturer and owner.
	63	6/1/1999	1	L.F. Eason (NC)	Yes	Parking brake needed on all carts that engages automatically when the operator releases the control or returns it to a neutral position. Otherwise, a walk behind left on an incline could run over operator.	Add parking brake requirement.
	78	6/1/1999	1	Bill West (OH)	No	This is not practical. Sometimes it is desireable/necessary to move the cart while walking along beside it or behind it.
	85	1/1/1999	1	Sid Colbrook (IL)	No	Illinois carts are remote control operated. No operator stands on the cart. Not sure how this section applies, if it does, to our application. We have a place for an operator to stand; however, we do not use it when the cart is in the remote control po
	114	3/18/1999	1	Jim Price (MD)	Yes	Brakes should be adequate; should not specify the design. I have not seen carts with brakes that operate in this manner. Is this brake option presently available? Would manually operated brakes be sufficient?	4.3.1 Brakes. Weight carts shall be eqiupped with appropriate brakes.
4.3.2
	21	5/17/1999	1	WRAP	No	Power (CA]. Editorial concern. 4.3.2.1. [ID] do we need a gage stick or sight glass for the level of the gas, the expansion and contraction, etc.? How about making the gas tank removable? A quick-connect like is used on boats and the cart can be calib
	142	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: It has been suggested that we divide weight carts by type depending on how they are powered. This makes a lot of sense with respect to data related to mass stability during actual use. The intent here was to acknowledge and allow t
4.3.2.1
	33	6/1/1999	1	Tom Schafer (ID)	Yes	Add "or removable gas tank" - (cart calibrated without tank).	Add "or removable gas tank"
	55	6/1/1999	1	L.F. Eason (NC)	Yes	Think suitable should be defined by the amount of displacement of fuel in the gauge. An example would be: "The tank should be equipped with a fuel gauge that is sensitive enough that the volume of fuel weighing the nominal mass tolerance will deflect t	See "comments".
	109	3/18/1999	1	Jim Price (MD)	Yes	Omits diesel fuel tanks. Upper and lower limits are vague. This section appears to exempt diesel powered carts from the requirement of a fuel tank sight gauge. What are the upper and lower limits that are to be marked on the sight gauge, and must they	4.3.2.1 Fuel Tanks. Fuel tanks shall be equipped with a clear sight gauge that adequately represents the fuel level in the tank. There shall be an appropriate area adjacent to the sight gauge for marking the fuel level for calibration reference and for
	110	3/18/1999	1	Jim Price (MD)	Yes	Add section to require level indicator	Section X. Level Indicator. The weight cart shall be eqiupped with an adjustable spirit level mounted near the fuel tank.
	126	6/25/1998	0	Joe Rothleder (CA)	No	There may need to be some experimental work done to determine the error contribution of cart ware and/or fluid level variability relative to the actual load uncertainty. Remember the cart will only represent a fraction of the load. If we use the Hb 44 1
	131	6/26/1998	0	Jerry Clingaman (IN)	No	3. Carts must have visual sight gauge suitable for marking upper and lower fuel level limits as well as calibration level. (lab admin procedure # 15.6)
	143	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: evaluation of gas tank sizes and range of variability from full to empty as compared to the mass value and tolerances needs to be studied further (as suggested by Joe Rothleder). Cleaning up the wording to include diesel as suggeste
4.3.2.2
	17	6/15/1999	1	Ron Balaze (MI)	Yes	Hydraulic fluid levels. The most severe problem area seems to be the hydraulic fluid level. Could this be helped with a standard warm up time?	Start the engine and allow a 5-minute warm up period before checking/setting the hydraulic oil level.
	56	6/1/1999	1	L.F. Eason (NC)	Yes	This is a tough thing to judge. The hydraulic fluid level is too dependent on temperature. I agree the gauge should be there and think it should be a visible gauge rather than a dip stick, but don't think there is an easy way to reference it for calibra	Have a sealable cap.
	98	6/1/1999	1	Mike Cook (FL)	No	Hydraulic tank should be of sufficient size to allow for the expansion of fluid during use. There should be a reference temperature of the fluid at the time of calibration so the appropriate level can be reproduced in the field. It should be documented
	132	6/26/1998	0	Jerry Clingaman (IN)	No	4. Carts must have gauge or dipstick for checking hydraullic fluid level. (lab admin procedure # 15.6)
4.3.3
	5	6/15/1999	1	Weight Carts, Inc.	Yes	There is no reason stated for a cart to have 3 axels. I do not know what it would be. A minimum of two axles is only common sense unless there are specifications to determine minimum axle numbers or weight per axle. This section should be eliminated.	Eliminate section.
	12	6/15/1999	1	Ed Paladi (MI)	No	3 axles ok but need to be four wheel drive. Single axle drive has to work very hard to move the load on uneven ground or slopes.
	13	6/15/1999	1	Jim Brown (MI)	No	The weight carts in Region 1-2-3 is a 5000 lb cart with two axles. Requiring carts over 3000 lb to have three axles may add extra cost to a company that now may not buy a cart. As long as the PSI is not exceeded, having only two axles should not be a pr
	22	5/17/1999	1	WRAP	No	Axles. Number based on weight. Two or three? Number should be a function of the maximum load that will be carried. [MT] - certain CLC on the scales. [OR] has purchased a 5000 lb cart from CargoTec and indcated that it was designed to meet the footpri
	30	1/5/1999	1	John Pugh (SC)	No	What is the basis for the three axle requirement for carts larger than 3 000 lb. Why are carts less than 3 000 lb required to have two wheels per axle thus eliminated the tricycle type carts for testing livestock scales?
	38	6/1/1999	1	Ken Johnson (OH)	No	Restrict design for manufacturer.
	45	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	Another item that could restrict design/manufacturing, etc.
	49	6/1/1999	1	Dan Wright (WA)	No	Why a requirement for three axles on weight carts over 3 000 lb?
	57	6/1/1999	1	L.F. Eason (NC)	Yes	Axle requirements should be related to the capacity of the cart instead of the mass of the cart. Two issues are at stake here. One is the ability of the cart to support the weight. This can be addressed by requiring the cart to be built strong enough t	Get additional input and address both issues.
	76	6/1/1999	1	Bill West (OH)	No	Is it necessary to require more than 2 axles on carts over 3 000 lb? Unless we say that the PSI is too high, I see no reason to stipulate the number of axles.
	83	1/1/1999	1	Sid Colbrook (IL)	Yes	Why should the nominal mass, not capacity of the cart determine how many axles are under the cart? Does this statement cause liability? If someone has a 3 000 lb cart with two axles and the cart collapses, injuring someone and causing extensive damage,	We would recommend that 4.3.3. Axles be removed.
	90	6/1/1999	1	Mike Dynia	No	Weight carts with 3 axles might have a problem going over bumps. All weight carts have a minimum of 2 axles. If have 3 axles, would need joints to flex and go over bumps.
	111	3/18/1999	1	Jim Price (MD)	Yes	Axles need to be clarified. If this section is intending to require a minimum of 4 wheels on a cart of 3 000 lb or less and at least 6 wheels on a cart of more than 3 000 lb, I do not think it accomplishes the goal. The language should require a minimum	4.3.3 Number of Supporting Wheels. Weight carts that achieve a total gross weight, when loaded, greater than 20 000 lb shall be supported by a minimum of 6 wheels. Wheels shall be spaced to distribute the load evenly along the normal loading pattern of
	144	6/22/1999	1	G. Harris (NIST)	No	Not sure of source or reason for axle requirements.
	151	6/15/1999	1	George Shefcheck (OR)	No	I can see no need to specify the number of axles on a given weight cart. Engineers and weight cart manufacturers are already liable for making carts that are structurally sound and hold the specified weight. Our division recently purchased a 5 000 lb we
4.3.4
	34	6/1/1999	1	Tom Schafer (ID)	Yes	No tread allowed.	No tread allowed.
	152	6/15/1999	1	George Shefcheck (OR)	No	Requiring a minimum of two treadless tires on each axle simply does not make sense in OR. Weight carts are an integral part of our livestock testing program. Most livestock scales in the State are inaccessible to our trucks. Without weight carts, they'
	153	6/23/1999	1	G. Harris (NIST)	No	Concern regarding accessibility to scales with treaded/untreaded tires can be handled with the General Code Requirements in HB 44, "G-UR 4.4. Assistance in Testing Operations. If the design, construction, or location of any device is such as to require
	154	6/23/1999	1	G. Harris (NIST)	No	Comments regarding treaded tires acknowledge that dirt and debris are picked up. Any scale rejected with such a device could easily be challenged in court with having to "prove" that the accummulated dirt and debris does not exceed the 1/3 tolerance requ
4.3.4.1
	6	6/15/1999	1	Weight Carts, Inc.	Yes	There are small carts to carry weights that have only 1 tire on the axle. This section is small, but says too much and does not cover all designs. The only part of this section acceptable is to use treadless or smooth tires.	See recommendations on section 4.3.4.2.
	23	5/17/1999	1	WRAP	No	[CA] editorial - treadless tires. Intent: Livestock situations and contamination. Should we measure rubber. Discussion held over what sticks to the tires "more".
	58	6/1/1999	1	L.F. Eason (NC)	No	Is there any reason to specify that these be solid instead of pneumatic? Treadless should be emphasized. Could tread thickness be measured with calipers at the time of calibration as a stability monitor?
	77	6/1/1999	1	Bill West (OH)	No	Shouldn't we stipulate solid tires? Or is it ok to use pneumatic tires?
	118	3/18/1999	1	Jim Price (MD)	Yes	If wheels are mounted on spindles with hubs or to hydraulic rotors (drive wheels), it would be impossible to place two tires on an axle.	Weight carts shall be equipped with treadless tires sized to prevent overloading of scale platforms.
	130	6/26/1998	0	Jerry Clingaman (IN)	No	2. Carts must have smooth (non-treaded) tires. (lab admin procedure # 15.6)
	145	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: material being picked up in tires adds mass to the cart and increases the variability of its mass. The amount added can be pretty significant. Treadless tires should be used.
4.3.4.2
	7	6/15/1999	1	Weight Carts, Inc.	Yes	Combine tire size and type in this section. If Handbook 1051- is to give specifications on weight carts, do not refer to other sources for more specifications. Put information that pertains in the proper section.	Tire sizes and style should be chosen so as not to overload the scale platform or accumulate foreign materials. A smooth tire is prepared [preferred].
	146	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: CLC and footprint of an actual truck.
4.3.5
	112	3/18/1999	1	Jim Price (MD)	Yes	Language needs to be clarified; holes for drainage may not be practical. Water may be trapped on surfaces that cannot be drilled with holes, air breather covers, in wheels, on rails that contain hydraulic fluid, etc..	4.3.5. Drainage. The weight cart shall be so designed to prevent the accumulation of water on its surfaces.
	147	6/22/1999	1	G. Harris	No	Intent is to avoid material (rain, water, snow) sitting on the surface that will add weight to the cart. AAR Handbook states "smooth and sloped top to ensure drainage," "a minimum of ledges, cavities, or projections that will hold dirt, water, or other
4.3.8
	18	6/15/1999	1	Ron Balaze (MI)	Yes	The sealing cavity must be permanently affixed to the cart (I.e., welded) or sealable to the cart. Some of the cavities are currently bolted to the cart with no provision for sealing.	Permanently affixed sealing cavity.
	113	3/18/1999	1	Jim Price (MD)	Yes	Change to adjustment cavity. Specify how to attach to cart, clarify sealing.	Change Sealing Cavity to Section 4.3.8 Adjustment Cavity, and add: The adjustment cavity shall be permanently attached to the chassis or frame of the weight cart or there shall be provision for affixing a wire seal in a manner that requires the seal to b
4.3.8.1
	59	6/1/1999	1	L.F. Eason (NC)	Yes	Needs to specify that the adjustment cavity needs to have a capacity of approximately 50 lbs above and below the nominally adjusted mass	Specify adjustment cavity size of +/- 50 lb from nominal.
4.3.8.1.1
	97	6/1/1999	1	Mike Dynia (CT)	Yes	Add a requirement that opening of sealing cavity be minimum of 2 1/2 inch diameter, maximum 3 in diameter. To facilitate adjusting the weight cart.	Size of opening for sealing cavity suggested.
4.3.8.2
	60	6/1/1999	1	L.F. Eason (NC)	No	Suggest having a separate section on sealing describing everything that needs to be sealed. These would include adjustment cavity, adjustment box to cart, battery cover, hydraulic fluid cap, and fuel gauge to tank. These suggestions are not to prevent f
	101	6/1/1999	1	Brenda Whitener/Jens Paulsen (GA)	Yes		Add: The seal should be a moisture tight seal to prevent moisture penetration.
4.3.8.3
	61	6/1/1999	1	L.F. Eason (NC)	Yes	Mercury? Probably specify solid metal I guess. Also might help to mention that the size of adjustment pieces must be small enough to be easily removed.	Specify solid metal.
4.3.9
	62	6/1/1999	1	L.F. Eason (NC)	Yes	I would change title of section to "Balanced Lifting of Cart"	See comments.
	84	1/1/1999	1	Sid Colbrook (IL)	Yes	Altough the concept is good, this may create a liability. If a cart leaves a Metrology Laboratory, and later falls from the hoisting equipment, calibration personnel may be held accountable because the cart was not absolutely level. After injury or dama	We would recommend that Section 4.3.9 Level Construction be removed.
	148	6/22/1999	1	G. Harris (NIST)	No	Intent: if a cart is picked up by a load cell or balance (rather than sitting level on a deck), having the cart balance level affects the ability to test properly. Not having weight evenly distributed over the footprint of the cart may have other implic
4.4
	190	9/5/2001	2
4.4.1
	46	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	Could parts be galvanized, stainless, epoxy, etc.?
	115	3/18/1999	1	Jim Price (MD)	Yes	Enamel paint should not be specified and all surfaces may not be painted.	All painted surfaces shall be maintained with a high quality wear resistant paint.
4.4.2
	191	9/5/2001	2	VM	Yes	Wording: maximum "safe" loaded weight vs maximum capacity? E.g., 25,000 capacity? Carrying load? Net/gross? Maxiumum gross weight.	Change to Maximum Gross Weight.	Don't use "safe" either.
	192	9/5/2001	2	JD	no	Do we need specified sizes on the ID plates? Minimum size?		Prominently and cleary displayed. Check on font sizes or minimum sizes.
4.4.2.2
	24	5/17/1999	1	WRAP	Yes	Content of ID plate. The plate shall contain 1) nominal mass….. Need to add "maximum capacity of the cart."	Add - "maximum capacity of the cart"
	64	6/1/1999	1	L.F. Eason (NC)	No	Should engine (motor) horsepower, manufacturer, and / or serial number be listed on plate to clearly identify that the engine is the original?
	99	6/1/1999	1	Mike Cook (FL)	No	Should there be a maximum capacity identified by the manufacturer?
4.5
	193	9/5/2001	2	EH	No	Other types of fuels? Discussion of electric carts.	Delete all but the first sentence in the first paragraph.	CNG wouldn't be ok. BA: functionally in support of saying preferred electric carts. SC: in doing large capacity scales, they end up in court more than anything else. It would be used against them in IL. Would prefer not having "preferred" either. Wou
	194	9/5/2001	2	EH	No	Why specify the power transmission?		It doesn't restrict design. It widens the methods for transmitting power. Needed to allow the hydraulic coupling.
4.6
	195	9/5/2001	2	VM		Fuel tank capacity.		SC: not really an issue; more of a concern in dealing with retroactivity. VM: one example of a cart going down a rail road. BA: it is a necessity because it is one of the few things we can control for the users.
	220	9/6/2001	2	BA	Y	Color of fuel tanks.	Painted white; not black
4.6.2
	196	9/5/2001	2	VM		Operators more likely to maintain within a range rather than at a reference level. 10 cu in based on the mass of the fuel. (Is 20 cu in doable in a vehicle scale test). 1 gal/hr under load? 25 HP engine at full throttle was 1.7 gal/hour. This is abo	Resolution: have a graduated scale based on 1) scale divisions being tested and 2) based on volume. (both correspond to a mass vs tolerance value.)	Should be a function of the tolerance of the cart. How much of the tolerance can be used by variability of fuel use? The engine size doesn't change as much on the cart capacities. Calculations are based on working backwards from HB 44. This calculates
4.6.3
	197	9/5/2001	2	VM/LF		Background on CO design. Graduation width or a cross sectional area on the fuel tank.	Graduation width may be easier to verify.	Sensitivity of the neck is the concern. Compare to 105-3. EH: finds this clear. BA: A lay person can determine a cross sectional area easier than a volume.
4.6.4
	198	9/5/2001	2	VM	No.	We need some means of measuring the temperature; but it is only significant if we can figure out some way to do something with it.		May only need it for the laboratory calibration. E.g., petcocks on top load provers.
	199	9/5/2001	2	EH/GH	Yes	Need to have a readability on the thermometer.	Use 1 F readability on the thermometers.
4.6.5
	200	9/5/2001	2	VM
	201	9/5/2001	2	gh	Yes	Take out "So that" and beyond.	Delete end of sentence.
4.7.1
	202	9/5/2001	2	VM	No	Background information.
4.7.2
	203	9/5/2001	2	VM		Background info. Some carts will have a problem with this. Problems with spilling fluids when it is hot. Retroactivity will be an issue.		Concern about contained/sealed reservervoir. It must be adjustable..
4.7.3
	204	9/5/2001	2	GH	N	Add readability of the thermometer.		Need to see what's available.
	205	9/5/2001	2			Concern about the number of thermometers and sizes of the thermometers and breakage.
4.7.4
	206	9/5/2001	2	GH	Y	delete "so that" and beyond.	delete end of sentence
4.7.5.
	207	9/5/2001	2	GH	Y	delete "so that" and beyond.	delete end of sentence.
4.8.1
	208	9/5/2001	2			Engine reservoir - no control over size. Needs to be set in the lab and not operated for a specified period of time; no way to put a thermometer in.		LF: concern over temperature requirements; concern over temperature calibration requirements; may put into question the weight of the cart. Increases the time it takes for cart calibration. Some labs won't be able to test. If the reservoir is sealed w
4.8.2
	209	9/5/2001	2	VM	Y	delete "so that"	delete after "so that"
4.8.3
	210	9/5/2001	2	VM		BA: Do we need this?	Mounting of the engine oil filter should be done to prevent contamination	Punch a hole in the horizontal filter and put a butter bowl under it (JD). (Maintenance guidelines.)
4.9
	211	9/5/2001	2	VM	Y	Background on potential damage to scales. Some old scales are still in service.	Remove?	LF: can we just talk about the number of wheels? Previous discussion on draft 1 supported not requiring axle limitations.
	212	9/5/2001	2	LF	Y		The number of wheels must support the gross weight of the cart and contact pressure will not exceed the CLC.	JD: Weight carts with a loaded weight of 3000 lb or more shall have a minimum of 4 tires. (?)
5
	29	1/5/1999	1	John Pugh (SC)	No	Based on calibration methods and uncertainty analysis they feel comfortable using test weight requirements of HB 44.
	31	1/5/1999	1	John Pugh (SC)	Yes	Would prefer that the tolerances be 5 000 lb. +/- 1.5 lb rather than +/- 1.0 lb.	Set tolerance at 1.5 lb for 5 000 lb cart.
	65	6/1/1999	1	L.F. Eason (NC)	Yes	I would suggest that we have adjustment tolerances and maintenance tolerances. The adjustment tolerance should be the same as the class F tolerance and this is what all carts should be adjusted to. The maintenance tolerance should be 1/3 the typical HB4	See comments.
	91	6/1/1999	1	Mike Dynia (CT)	Yes	Change tolerances to one part in 3 000. 3 000 lb = 1 lb. 5 000 lb = 1.5 lb. I believe that the standard will still meet the accuracy requirements of 3.33 lb, plus you will adjust the cart to zero error.	Change tolerances - see comments.
	116	3/18/1999	1	Jim Price (MD)	Yes	Delete acceptance and maintenance tolerance reference, eliminate reference to HB 44. When do we apply acceptance or maintenance tolerances to a weight cart? The application of HB 44 recommendations of tolerances to standards to derive an appropriate tol	5. Tolerances. The tolerances applied tp weight carts are one part in 5 000. Tolerance for a 3 000 lb cart is +/- 0.6 lb.
	149	6/22/1999	1	G. Harris (NIST)	No	Factors to consider: weight carts should be adjusted to zero error. Expanded uncertainty should be less than 1/3 of whatever tolerance we choose to apply. The uncertainty should take into consideration such factors as fluid levels and reference tempera
	248	9/6/2001	2	LF	Yes		Use wording sample from 105-3, section 5.1 and modify for weight carts.	Do we need to deal with the "use uncertainties" for weight carts and the relationship to HB 44. (Carts to be adjusted to zero; application of this tolerance needs to be addressed.) NOTE: The entire portion of the HB 44 fundamental considerations are be
5.2
	9	6/15/1999	1	Weight Carts, Inc.	No	Unsure of what is stated: Is tolerance to be 1 lb for a 5000 lb cart or 3.33 lb as stated in HB 44 for a standard?
5.3
	25	5/17/1999	1	WRAP	No	Tolerances. All are actually 1 part in 5 000. Why have three sections? Now have 1 part in 10 000. [MT] If it doesn't meet Class F - the Conference may not adopt it.
6.1
	47	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	If a scale company has a suitable scale, why can't the verification be done in house and witnessed?
	250	9/6/2001	2	LF		The cart "must be" reverified if damage is known or suspected.	If damage to a weight cart is known or suspected, it must be reverified.	GH: Terminology of verification must be clarifies: implies inspection and calibration and evaluation of specifications and tolerances. Split into two paragraphs. EH: consider if there is a VIM or OIML definition and conflicts.
6.2
	66	6/1/1999	1	L.F. Eason (NC)	Yes	I would suggest breaking this down into three sub-sections. The first (6.2.1) would deal with routine maintenance. Even in this section, it should be suggested when possible that before maintenance as found data should be collected for the cart. The po	See comments.
	251	9/6/2001	2					BA: concern about the number of seals and tamper indicating items; keep it to a small number. LF: is the inspector has the mentality that if something isn't marked, it can be changed. Where is the limit. We need to realize that changes are not going t
6.3
	67	6/1/1999	1	L.F. Eason (NC)	No	This section seems to classify these as field standards. Do we want to?
	252	9/6/2001	2					No comments.
6.4
	26	5/17/1999	1	WRAP	Yes	Calibration Reports. [MT] Standard uncertainty for a weight that has 1 part in 5 000?	Delete uncertainty requirement.
	92	6/1/1999	1	Mike Dynia (CT)	Yes	Inspection checklist - delete. Let States determine what kind of worksheet they want to use. Using the term makes it a requirement.	Delete the inspection checklist.
	96	6/1/1999	1	Mike Dynia (CT)	Yes	Calibration Reports. Add statement on the report that the weight cart meets the accuracy requirements of HB 44 - that a standard not have an error greater than 1/3 the smallest tolerance to be applied. This should be on the report.	Include statement on report.
	107	6/1/1999	1	Mike Kramer (VA)	Yes	Include battery on report. I have started using the phrase "when used in conjunction with batter xx, serial # xxy". The battery is part of the cart which we find is changed most frequently, with the biggest effect on the weight.	See comments.
7.1
	68	6/1/1999	1	L.F. Eason (NC)	No	This will not work for the proposed tolerances since they are double the class F tolerance. Therefore as stated the uncertainty of the standards alone will be the class F tolerance and will be 1/2 the cart tolerance. By time the scale and other componen
	104	6/1/1999	1	Tom Smith (TN)	Yes	I feel the use of field standards to calibrate the weight carts will introduce too much uncertainty. I feel as a minimum, working standards should be used. In most cases, corrections are not applied with the use of field standards. Since calibration is	Require use of working standards.
	253	9/6/2001	2					No comments.
7.3
	93	6/1/1999	1	Mike Dynia (CT)	No	Weighing device - Since the weight cart is not considered Class F field standards should not specify equipment or standard deviation of the balance to be used as long as weight cart can be calibrated to meet 3:1 accuracy requirement, using modified substi
7.3.
	86	1/1/1999	1	Sid Colbrook (IL)	No	To ensure credibility, a weight cart must be calibrated with equipment comparable to that which is used to test Class F field standard weights.
7.4
	27	5/17/1999	1	WRAP	Yes	Inspection checklist. [CA]. Calibration and verification. Need to define the test, use, and conditions and fluid levels. Include a sample as an appendix. [NV] Is the same thing done with railroad test cars? [WY] Yes. [CA] Certificate must indicate	1. Include a sample checklist as an appendix. 2. Include a seal on anything removable.
	69	6/1/1999	1	L.F. Eason (NC)	Yes	Good idea, but we need to specify what should be included and probably include an example as an appendix (to the appendix? - still think it's different enough to warrant separate 105 status). Things that should be included: paint color and condition, oi	Separate 105. Include checklist as an appendix.
	79	6/1/1999	1	Bill West (OH)	No	What is included on the checklist? Is it to be part of the appendix or something each jurisdiction develops on its own?
8
	70	6/1/1999	1	L.F. Eason (NC)	Yes	Contradicts the establishment of a 2 times class F tolerance. If we use this approach, we should settle on a weight cart tolerance of 3.33 lbs and require a worst case expanded uncertainty of 1.11 lbs. I think this is too high and is beyond existing cap	See comments.
	94	6/1/1999	1	Mike Dynia (CT)	No	Uncertainties - change Class III to IIIL, 5 000 lb weight cart with 5 000 lb of weights will meet 1 part in 5 000 lb.
	254	9/6/2001	2	GH		It needs to be expanded to include identificaton of variables associated with use.
9
	117	3/18/1999	1	Jim Price (MD)	No	Remove reference to User Requirements. The term "user requirement" in a HB 44 term directed toward the method of device use that is enforced by weights and measures field inspectors. If these user requirements are published in HB 105-1, directed toward
9.1
	10	6/15/1999	1	Weight Carts, Inc.	No	As in section 4.1.1 we do not see the specifications as to why the carts are to be used with weights four times the weight of the cart. More information is to be included in the section stating reason or specification for this.
	35	6/1/1999	1	Tom Schafer (ID)	Yes	Add a comment related to uncertainties.	add "if the uncertainty of the weight cart exceeds Class F requirements."
	48	6/1/1999	1	L. Edward Luthy (Brechbuhler Scales, OH)	No	Does this mean you must use 12 000 lb test weight and 3 000 lb cart as a minimum test load?
	71	6/1/1999	1	L.F. Eason (NC)	Yes	This is not going to be done and should not be included as long as adequate calibration is available. With some analysis it could be used when cart calibration systems are not adequate to provide the required level of uncertainty. In this case it would	Eliminate requirement as stated.
	87	1/1/1999	1	Sid Colbrook (IL)	No	Same question as listed in Section 4.1.1 Size Limitation.
	102	6/1/1999	1	Brenda Whitener/Jens Paulsen (GA)	Yes		The total capacity of the weight cart shall be based on the weight requirements as set forth in Handbook 44 (I.e., 25% of scale capacity).
	119	1/13/1999	1	Craig Olsen (NE)	No	Under Section 9.1, According to this section, a 3 000 lb cart must be used with 12 000 lb of Class F field standards to make a total of 15 000 lb. According to the next paragraph, a 3 000 lb cart could be used alone on a 10 000 lb x 1 lb scale (maintenan
	122	6/22/1999	1	G. Harris (NIST)	Yes	There have been a number of comments received regarding User Requirements and an appropriate location for comments regarding use in the field. None of the other 105-x handbooks cover User Requirements. Comments were received prior to the development of	Eliminate section 9, User Requirements. However, in Section 5, ensure that tolerances and calibration practices and uncertainties are adequate for use of the devices under no-load conditions. Actual practices regarding calibration intervals may also nee
	255	9/6/2001	2	GH	Y	change to "gross loaded weight" wording here too.	May be used alone or in combination with .. As long as the requirements of HB 44 are met/maintained. Change maximum safe loaded to gross loaded weight.	Question about using it "in combination". May be used alone or in combination with. It's already permissive language.
9.2
	11	6/15/1999	1	Weight Carts, Inc.	No	Reword: All items on the inspection checklist must be inspected - fluids to be checked, etc..
	50	6/1/1999	1	Dan Wright (WA)	Yes	On line two - delete "fluids must be" reason; double entry typo.	Fix typo.
	72	6/1/1999	1	L.F. Eason (NC)	Yes	Should be made a part of scale test report. Should list what should be checked and attach an example.	See comments.
	80	6/1/1999	1	Bill West (OH)	No	Must have lost something in this paragraph.
	95	6/1/1999	1	Mike Dynia (CT)	Yes	Type mistake. Checklist fluids must be, eliminate must be.	See comments.
	103	6/1/1999	1	Brenda Whitener/Jens Paulsen (GA)	Yes	Question: Is it the intent to top off the gasoline tank after each test? The consumption of gasoline per test is averaging approximately 1 pint or approximately 1 lb.	Fix typo in first sentence.
	123	6/22/1999	1	G. Harris (NIST)	Yes	Eliminate Section 9.2	In Section 6.4 retain an "inspection checklist" as a required part of the calibration report and include a "suggested sample" as an appendix.
	256	9/6/2001	2	GH	Y	delete the use of the word certified.	change certified to calibrated. Changed measured to calibrated.
	257	9/6/2001	2	DE		concerns about obtaining "as found" values require calibation, maintenance, and calibration.		How do you know that the last scale that was tested/rejected was done with good weights/cart if you clean, paint, or maintain prior to test and calibration? The requirements are already there. It's just a matter of time when "as found" gets challenged.
9.3
	73	6/1/1999	1	L.F. Eason (NC)	Yes	Describe cleaning method so that people don't sandblast and paint carts. Could simply say that cleaning method must change the mass of the cart. Would also mention that between calibration painting should be limited to wire brushing bare rusting area an	See comments.
	150	6/22/1999	1	G. Harris (NIST)	No	These are user requirements. A few as found values could demonstrate the extent to which lack of cleanliness would cause out of tolerance conditions.
	258	9/6/2001	2		Y		delete "must be" when used in duplicate.
	259	9/6/2001	2		Y		add an "and" after the comma.	LF: should checklist be attached? GH: idea of having a "weight cart handbook".
9.4
	260	9/6/2001	2					Rain: can affect the cart by 2 to 4 lbs (not including the weights). (It was a fairly small cart). DE Timing is everything when it's raining (zero tracking). AZT is deactivated/turned off during test..??
AAR Scale HB
	52	6/1/1999	1	L.F. Eason (NC)	No	The three classifications echo what I would recommend, different classifications for different type of weight carts. These would be differentiated primarily by fuel types Gasoline Diesel Electric (battery) Electric (extension cord?) Primary requirem
Background
	51	6/1/1999	1	L.F. Eason (NC)	No	Too much emphasis is being placed on these carts meeting Class F tolerances. As discussed below, these should not be confused with class F weights and more emphasis should be put on assuring that they maintain 1/3 the applicable tolerance of the device t
General
	15	6/15/1999	1	Ron Balaze (MI)	Yes	We may need to have three sections in the document: 1. Class III Scales. 2. Class IIIL and IV Scales. And 3. Electric Carts.	1. Class III Scales - must maintain HB 105-1 Class F tolerances. (Must be used with test weights?) 2. Class IIIL and IV - must maintain a new tolerance - (1 lb or 2 lb?) 3. Electric carts - must maintain HB 105-1 Class F tolerances.
	16	6/15/1999	1	Ron Balaze (MI)	No	Based on the limited data we have at this time (3 month to 6 month) calibration intervals may be needed.
	105	6/1/1999	1	Mike Kramer (VA)	No	I feel this draft is written well, and is overdue. I have had scale companies wanting to manufacture their own weight carts out of old forklifts. It will be nice to have a standard to refer them to.
	121	6/22/1999	1	G. Harris (NIST)	Yes	Based on written feedback from the first draft and the type of comments I have heard, we will develop this handbook as a separate 105-X handbook rather than adding it as an appendix to 105-1.	Produce a NIST Handbook for the "Specifications and Tolerances for Weight Carts Used in Testing Vehicle Scales".
	128	6/24/1998	0	Jim Ross (OR)	No	OR has two gas carts. One is a 5 000 lb gas powered hydraulic cart from Cargo Tech and the other is a 2 500 lb cart that is being built locally. Administration decided to allow gas powered carts in OR and to calibrate to HB 44 tolerances. This was of s
	129	6/26/1998	0	Jerry Clingaman (IN)	No	1. Carts should be driven into the lab under their own power to avoid drive train damage. (lab admin procedure # 15.6)
	134	6/26/1998	0	Jerry Clingaman (IN)	No	6. Cart engines will be well tuned, to eliminate as much exhaust odor as possible before being taken into the laboratory. (lab admin procedure # 15.6)
	135	6/26/1998	0	Jerry Clingaman (IN)	No	7. Carts shall have all repairs and/or maintenance done before calibration. (lab admin procedure # 15.6)
	137	6/26/1998	0	Jerry Clingaman (IN)	No	Also advise cart owners to weigh their battery to help in maintaining correct calibration.
	157	9/5/2001	2	BA	yes	HB 44 - concept of retroactivity. It can be detrimental to push the envelope. We should have a compliance date, but we also need to be realistic about the date and make it palatable. (Val: explanation of timeline proposed).	2006	SC: clarification of components to be retroactive. New carts - all components should be met. VM: no way some existing carts will meet. We need to pick the critical issues (e.g., fuel carts). LFE: concern about precedent setting with the 105-series
	158	9/5/2001	2	VM	y	Concerns about manufacturing specifications - queries coming in.	finish the draft
	160	9/5/2001	2	LFE	Y	Retroactivity issues if "the cart maintains its stability".	Suggest leaving the other 105 verbage in place as non retroactive.	GH/VM: concerns about fuel tanks and "user abused" features of the carts.
	162	9/5/2001	2	VM	No	Modifications of carts to make them grow or shrink - each cart will likely have to be uniquely modified. (LFE - structural integrity features).
	249	9/6/2001	2	LF		Use extra comments from the other 105's in this document as well.
Introduction
	28	5/17/1999	1	WRAP	No	[LAC] In reading the scope - it only addresses large carts. What about 50 lb carts? Stainless steel carts with hard plastic wheels? Or holders? Hand carts? Putting the small carts in? [CA] Suggest we start with what is being screamed for now - for c
	88	6/1/1999	1	Mike Dynia (CT)	Yes	Delete Class III Scales - limit use to Class IIIL and IV.	See comments.
Scope
	247	9/6/2001	2	VM				May need to change scope to delete Class III. DE: as a user, they would only use a cart on a class IIIL scale (and not Class III). Risk damage to load receiving elements. (??Decision).

By Weights and Measures Division, G. Harris
Email: gharris@nist.gov

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Date created: December 31, 2001
Last updated: October 1, 2002

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