According to FDA the basis of contents declaration is the same framework-drained weight or net weight-as the serving size declaration in the nutritional labeling. This change would require costly labeling revisions for a number of food labels said NFPA's Director of Technical Regulatory Affairs Regina Hildwine. These costs were not included in FDA's regulatory impact analysis of its proposed rule. In its comments to FDA NFPA argued that the proposed changes constitute a "significant rule" meaning FDA is required to study the impacts before proposing it. It urged FDA to withdraw the section of the proposed rule necessitating any changes in the basis of contents declaration.