Robert Millman
508 Lindsay Ave, Scotia, NY 12302
r.millman at att.net
3/5/07
Evelyn J. Aquila
Commissioner
NYS BOARD OF ELECTIONS
40 STEUBEN STREET
ALBANY, NY 12207-2108
Re: Poling Place Voting System Requirements § 6209.2
I’m writing to present information which indicates that DRE VVPATS
created via direct thermal printing cannot meet New York’s legal requirement to
“remain fully readable without degradation for 22 months” as required by
New York State Law. (Section 6209.2 Polling Place
Voting System Requirements)
The industry standards for thermal printing (of barcodes) is
posted by the organization, GS1 (formerly the Uniform Code Council, or UCC).
The GS1 specification for thermal printing, dated January 2005, states that “[d]irect thermal printing should be avoided whenever the symbol .
. . has a shelf life exceeding one year.”
To re-state, the trade organization
that sets U.S. and worldwide standards for the use of thermal-printed barcodes
has promulgated industry standards stating that direct thermal-printed paper
records degrade and are unreliable after 12 months.
The full text regarding thermal printed
barcodes under the heading “5.4.A.3.2 General Considerations for Direct Thermal
Printing” is reproduced below, with relevant text in bold lettering (emphasis
mine).
“[d]irect
thermal printing should be avoided whenever the symbol may be exposed to
direct sunlight or extreme temperatures or has
a shelf life exceeding one year. These labels fade very quickly in direct
sunlight, and the background darkens at elevated temperatures. Some
fading also occurs as labels age at room temperature under normal indoor
lighting. As labels fade or darken, the
contrast decreases so that at some point the symbol can no longer be scanned.
“An example of a good application for
thermal labels is in-store marking of meat and other perishable food items.
Such labels need last only days or weeks under protected indoor conditions.”
The above text regarding General Considerations for Direct
Thermal Printing can be found at—http://www.ean.se/GSV6.0/HTML_Files/Document_Library/Bar_Code/00103/05/05-04a3.html
General information regarding the GS1
organization can be found at—http://www.gs1us.org/
Robert Millman