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General Questions

I have confidence in Australia’s current measurement framework.

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I have the same confidence in those measurements I do not actively monitor (e.g. electricity supply) as those which I do (e.g. weighing groceries on a scale).

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To the extent that I have responsibilities, I know what my responsibilities are under Australia's measurement framework.

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On balance, measurement in Australia could benefit from greater:

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Previous Consultation

Would you like to provide your thoughts on the Scope of Australia's Measurement Law discussion paper?

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Which topic would you like to comment on?

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Dropdown list of Traceable Measurements, Measuring Instruments and Measurement-based Transactions
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Traceable Measurement - linking results with standards
Ticked Measuring Instruments - how they're approved
Measurement-based Transactions - buying and selling

Measuring Instruments

2.1.1. What costs/benefits are incurred by you or your business as a result of the current regulation of measuring instruments in Australia?

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Costs:
- NMI Pattern approval (Testing, assessment and certification)
- Meter Verification (NITP14)

Benefits:
- Using measuring instrument for trade and generate revenue.

While Pattern Approval cost is acceptable, NMI and relevant authorities must look into Meter Verification Process (NITP14). There are plenty of issues with current process.

1: Accredited Utility Meter Verifies are mainly product manufacturers OR product traders (not independent laboratory). They acquire accreditation to test their own instruments. When third party businesses (competitors), who do not have NITP14 accredited laboratory, approach local accredited verifies; they charge significantly high fee to test instruments under NITP14 i.e. taking huge advantage from unregulated costs. Such high verification costs create financial pressure on small importers/traders. In other words, major manufacturers and instrument traders force small importers to increase their prices because of high verification cost. This whole scenario creates monopoly for major market players affecting fare market competition negatively.

2: Currently NMI accepts local Australian labs as Utility Meter Verifies. This is another reason for major business to create market monopoly by charging extremely high verification fee (considering NITP14 costs are not regulated).

3: NITP14 fee/costs must either be regulated OR NMI should accept test results from overseas accredited labs. Only those overseas test reports should be acceptable where testing laboratory has same accreditation level as Australian NITP14 accredited labs.

For example, Australian labs are IEC 17025 certified (NATA Accredited). Overseas labs with similar qualification and ability to meet NITP14 specification should also be accepted as Utility Meter Verifies and their test reports should be acceptable to comply verification process/testing. Please note that most qualified overseas labs have local accreditation recognised by NATA Australia under ILAC (International Laboratory Accreditation Cooperation) and MRA (Mutual Recognition Agreement). If NATA Australia accepts overseas laboratory test results and accreditation, why such overseas can't be used for NITP14 instrument verification?

2.2.1. In your opinion, does the current legislative framework strike an appropriate balance between the interests of various parties in the supply chain? If not, how could current arrangements be made more efficient or effective?

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Current legislative framework doesn't create an appropriate balance between various parties. Major parties such as manufacturers or traders take unfair advantage of unregulated costs with regards to Utility Meter Verification Process under NITP14 specification.

1: Accredited Utility Meter Verifies are mainly product manufacturers OR product traders (not independent laboratory). They acquire accreditation to test their own instruments. When third party businesses (competitors), who do not have NITP14 accredited laboratory, approach local accredited verifies; they charge significantly high fee to test instruments under NITP14 i.e. taking huge advantage from unregulated costs. Such high verification costs create financial pressure on small importers/traders. In other words, major manufacturers and instrument traders force small importers to increase their prices because of high verification cost. This whole scenario creates monopoly for major market players affecting fare market competition negatively.

2: Currently NMI accepts local Australian labs as Utility Meter Verifies. This is another reason for major business to create market monopoly by charging extremely high verification fee (considering NITP14 costs are not regulated).

3: NITP14 fee/costs must either be regulated OR NMI should accept test results from overseas accredited labs. Only those overseas test reports should be acceptable where testing laboratory has same accreditation level as Australian NITP14 accredited labs.

For example, Australian labs are IEC 17025 certified (NATA Accredited). Overseas labs with similar qualification and ability to meet NITP14 specification should also be accepted as Utility Meter Verifies and their test reports should be acceptable to comply verification process/testing. Please note that most qualified overseas labs have local accreditation recognised by NATA Australia under ILAC (International Laboratory Accreditation Cooperation) and MRA (Mutual Recognition Agreement). If NATA Australia accepts overseas laboratory test results and accreditation, why such overseas can't be used for NITP14 instrument verification?

2.3.2. Do you have any further observations, issues or thoughts regarding the current regulation of measuring instruments?

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Please refer to 2.1.1 and 2.2.1

3.1.1. What is your experience regarding accessing or gaining pattern approval for measuring instruments?

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According to our latest experience with NMI, there are no pattern approval labs in Australia. Authorising overseas lab for pattern approval testing includes extra time and cost.

NMI should have a customer web portal where the process, issues, Q&A etc. could be logged. Such platform is always better than email communication.

The current process of NMI Pattern approval does meet market needs. NMI should be appreciated for accepting existing test reports and allow imports to do extra tests only. This approach is indeed very good and cost saving process for instrument importers looking for product pattern approval.

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

Open text field for response
Yes, verification and certification are an effective and efficient means for accuracy demonstration. Instruments must be deemed accurate before lawfully used/traded in Australia. While the purpose/objective of verification process is effective, there are issues with the approach how verification and certification are currently done.

1: Accredited Utility Meter Verifies are mainly product manufacturers OR product traders (not independent laboratory). They acquire accreditation to test their own instruments. When third party businesses (competitors), who do not have NITP14 accredited laboratory, approach local accredited verifies; they charge significantly high fee to test instruments under NITP14 i.e. taking huge advantage from unregulated costs. Such high verification costs create financial pressure on small importers/traders. In other words, major manufacturers and instrument traders force small importers to increase their prices because of high verification cost. This whole scenario creates monopoly for major market players affecting fare market competition negatively.

2: Currently NMI accepts local Australian labs as Utility Meter Verifies. This is another reason for major business to create market monopoly by charging extremely high verification fee (considering NITP14 costs are not regulated).

3: NITP14 fee/costs must either be regulated OR NMI should accept test results from overseas accredited labs. Only those overseas test reports should be acceptable where testing laboratory has same accreditation level as Australian NITP14 accredited labs.

For example, Australian labs are IEC 17025 certified (NATA Accredited). Overseas labs with similar qualification and ability to meet NITP14 specification should also be accepted as Utility Meter Verifies and their test reports should be acceptable to comply verification process/testing. Please note that most qualified overseas labs have local accreditation recognised by NATA Australia under ILAC (International Laboratory Accreditation Cooperation) and MRA (Mutual Recognition Agreement). If NATA Australia accepts overseas laboratory test results and accreditation, why such overseas can't be used for NITP14 instrument verification?

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Measurement-based Transactions - buying and selling
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