Robert Millman

508 Lindsay Ave, Scotia, NY 12302

r.millman at


Evelyn J. Aquila
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—

General information regarding the GS1 organization can be found at—



Robert Millman