Measurement in everyday life

I believe consideration should be given to an outcomes based system, rather than a rigid rules based system.
Also - new technologies now rule certain older test procedure points redundant.

The Act is a clear guide.
New technologies (e.g. - self calibrating digital weighing systems) need to be considered, investigated and proven as to their accuracy and benefits in real-life scenarios.

NITP's for weighing instruments are currently too prescriptive - in that technology has made certain test points redundant,
The weighing industry (licensed certifiers) together with NMI technical experts should review NITP's in real world scenarios - with industry demonstrating the ability of technological advances in weighing systems (self calibration). New, less rigid NITP's could then be formulated - which would result in less costly calibration procedures for owners of trade approved weighing instruments.

NMI should test and rate the various manufacturers devices.
Real world use of self-calibrating devices - where test reports (compliance testing of instrument) demonstrate that the device worked.
For example - an audit schedule of various weighbridges, which have all been calibrated by self-calibration only, could be undertaken to determine accuracy of the device,
Provision should still be made for penalties, if the devices are found to be sub-standard.
Results would determine which manufacturers devices are reliable, accurate - and can be approved for trade use.

Yes - our business is concerned about security, authenticity and integrity of measurement results associated with new technologies and their source of traceability.

Confidence in measurements based on new and advanced technologies can be supported by the measurement framework - by "workshopping" real world scenarios and liaising with weighing industry leaders.

Current barriers to adopting new technologies arising from the current measurement law framework are - the unreasonable nature of current rigid NITP's not allowing self-calibration, before trade use of a repaired weighing instrument can resume, particularly in the remote regional areas of our company's sites.

Yes - verification / certification does deliver on assuring traceability and confidence in measurement results for measurements used for trade and other legal purposes.

Considerable costs are incurred by our business as a result of the current requirements.

For example, if a weighbridge component fails at one of our regional sites -around 800 km from Adelaide - the cost to mobilise a Weighbridge Test Truck to site is very expensive.

With self-calibration software in Mettler Toledo's PDX system - the weighbridge could be repaired, calibrated and matched to 3 other weighbridges at site, within tolerance. This would be much more efficient and cost effective.

The current regulation of measuring instruments in Australia results in more benefits than costs for our business.

It ensures quantity as well as quality to our customers.

The current legislative framework does strike an appropriate balance between the interests of various parties in the supply chain.

The current system is fine

NMI could carry out audit checks at a new weighbridge installation fitted with the new technology.
The owner of the weighbridge could be given right to trade over the instrument, on the provision that ongoing monitoring by NMI is performed.

This would allow more rapid uptake of new technology - supplied by proven reputable manufacturers.

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I think the current process meets the needs of measuring instrument manufacturers/suppliers, servicing licensees and users of measuring instruments.

Yes - verification and certification an effective and efficient means of ensuring and demonstrating accuracy for the purposes to which they are applied.

However - consideration must be given to allow for use of self-calibrating devices - in future.

All trade weighbridges should have mandated two yearly re-verification periods.

This will give better assurance to customers that the instrument is accurate - no matter the size or reputation of the business.

The current framework, which aims to ensure the ongoing confidence of measuring instruments, does serve our needs.

The current law does create unnecessary burdens for business and the costs associated with them.

For example, at our regional sites - the requirement for full NITP calibrations following minor repairs to weighbridges can be costly.
This can result in delays for customers - waiting to use the weighbridge during the harvest period.
If self-calibration was tested and provisionally approved - this would remove these issues.

Self-calibration should be considered, investigated and provisionally approved.

A sliding scale based on value of goods per kg could be considered.

I believe it is appropriate to prescribe in law how certain goods should be sold - based on value of the goods.