Is this considered legal open carrying? (picture included)

[potcha]

I do some walking and do not wear pants with belts and am a bit too large for shoulder holsters. Since I don't have my CPL, I have to open carry. My solution was to wear my gun openly on the outside of my backpack. I achieved this by adding Velcro tape to the holster and the backpack and tightly tying the bands of the backpack around the outside of the holster. Since this is clearly visible, this would be legally open carrying still, correct?

[Shadow Bear]

Perhaps, but tactically, there are concerns. It appears to be at the very rear of the pack, well out of your visual field. In a crowd, it could easily get snatched.

There are some duty belts that fasten with velcro that could be worn over your clothing, and provide a secure, tactically sound  method to keep your sidearm handy.

http://www.midwayusa.com/find?usersearchquery=belt&itemsperpage=24&newcategorydimensionid=15937

[32_d3gr33s]

You can carry a (gasp) long gun strapped (don't do it) to your back so I don't see this being much different.  Open is open. Personally I would not carry like this for a number of reasons...  You can get cheap drop legs online that will fit most pistols. Or  like shadow said, get a tac belt for carrying   

[TheQ]

I have concerns about it being snatched and your ability to readily access it when you need it.