Measurement in everyday life

3.2.1.a.
It has been effective, being from the Weighing Industry we work in SI base units (kg) which is part of the ALUM. The provision in the Act is effective and important to provide certainty to traceability.

3.2.1.b.
There should not be alternative mechanisms or frameworks in regard to Weighing that allow anything other than certainty to traceability including reference to ALUM.

3.2.2.a.
Making traceability assurance mechanisms more accessible for non-trade measurement purposes currently occurs to degrees in areas such as the examples given – Maritime, Safety, Health, Medical etc. Mechanisms are usually in place in these fields via Quality Assurance regimes (ISO) or other Legislated requirements that draw from results obtained from Trade Approved and Certified units. This is most certainly due is the traceability aspects where there is a large degree of confidence, integrity and traceability in the results obtained due to the processes in meeting these Trade requirements.
There are no benefit to be gained providing traceability assurance mechanisms that could be construed as 'compliant' in some form or another. In fact, quite the opposite, areas such as Maritime, Health, Safety, and Medical should be tightened to require the same traceability in Processes (NITP) as well as testing equipment used (Reg. 80 etc.) that ensures a degree of confidence and integrity, especially if litigation eventuates. An example would be Medicine administered by the Weight of a Person (on a large platform 150kg scale) that is lethal if administered by an incorrectly weighed dose (on a Lab Balance weighing in grams); in this example there are two weighing systems that would be at question in litigation. NMI's (National Measurement Institute) reach should be extended beyond Trade applications to include all areas measurement related and not by pseudo traceability assurance mechanisms.

4.2.1.a.
The current measurement framework has the right balance, the prescriptive nature provides reference and traceability.

4.2.1.b.
Flexibility could be incorporated when introducing new technologies where the testing procedure or NTIP's could be developed in conjunction with the manufacturer. Then allowing flexibility within the Pattern Approval process to dictate the testing procedure or NTIP rather than having to develop NTIP's that try to be an umbrella across like for like applications. This would assist in bringing new technologies to market quicker if that new technology doesn't have a relevant NTIP, as delays in NTIP creation can be years.

4.2.1.c.
If specifically for the traceability of measurements of physical quantities, a principals based approach would not be practical as weighing requires definitive results which maintain integrity and confidence.

4.2.2.a.
With regards to weighing devices to provide Legal assurances there would need to be traceability of the built-in reference used and defined testing periods to ensure accuracy is maintained and sustainable.

4.2.2.b.
Ideally in all trade and high risk areas and that would be required to give Legal assurances in litigation.

4.2.2.c.
Verification of built-in references would assure traceability by the very nature of a Verification process. The issue with any Verification process is that there needs to be periods of reverification to ensure ongoing accuracy. To this end the built-in reference needs to be in a medium that can be independently re-verified by a governed process at prescribed periods.
The built-in reference would need to be proven to be consistent over time and therefor would require independent verification of reference and instrument. With regard to say a metrological built-in reference being used to calibrate an instrument, the reference would need to be removed and independent tested for verification. Perhaps verification periods for the reference could extended for systems where access to the reference or methods of reverification do not facilitate ease of independent verification.

4.2.2.d.
It is very important, if a device is purporting to be Legal for Trade Use via this self-calibrating method, then it is extremely important that the use or application of the device complies with the Legal for Trade requirements. If so the user should be able to trade over the device with a heightened degree of confidence, they are both meeting the requirements of a device used in trade and are supported by a robust legal framework. This would become important in litigation.
Example:
Without the support and acceptance of a device by a legal framework, the user would have very little argument against trading over a device not fit for trade. Nor any ability to prove any degree of accuracy of traded quantities.

4.2.2.e.
The government / NMI should be involved in the process of assuring traceability in all matters relating to measurement. Traceability should be governed centrally by one entity. Pattern approval of all such devices and follow up with a conformity to type (compliance) program.

4.2.3.a.
Yes

4.2.3.b.
Yes

4.2.3.c.
Confidence will vary in differing areas. Where measurements are tangible and directly attributed by a process then there would be greater confidence. Where the measurements have appropriate gauge to be held against there should be confidence. Where the measurement is less transparent with a degree of sophistication is where confidence will become much harder to obtain. The current M7 POS Approval is a good example of how to achieve confidence in new and advanced technologies by supplementing the measurement framework.

4.2.3.d.
The need to comply with a framework that doesn't easily enable new technologies to be explored can be challenging. Delays in the Pattern Approval process in the areas of weighing technology within NMI does create barriers to bring product to
market in a timely manner, more resources are required in this area.

4.2.4.a.
Initial verification when a device is first calibrated and certified provides a great deal of confidence in the measurement results, which does deliver on assuring traceability in the short term. Confidence in measuring results being repeatable over several years of service cannot be assured though, so here are traceability concerns. Without a re-verification period ongoing accuracy cannot be assured as being accurate as when the device was first verified, so here are confidence concerns. Through the NITPs, the trade measurement system is well developed. Further improvement would be gained by introducing mandatory re-verification periods.

4.2.4.b.
To maintain confidence in measurement results would require results to be re-evaluated over time to gauge the effects of in-service use, environment, wear, tear, etc. To ensure the device actually does maintain its accuracy with all the aspects that can impact on a device's performance and long-term accuracy. Reverification periods should be mandated to give both the buyer and the seller confidence in measurement results over prolonged periods of in-service operation. It would also provide greater confidence to export markets of our GDP.

4.2.4.c.
No. The current system for weighing has evolved over many years, providing traceability to standards and of results.

4.2.5.a.
With regards to weighing, introduction of mandatory re-verification periods to ensure the constitutional rights of all Australians in equity of trade over prolonged periods of a devices in-service use.

4.2.5.b.
As a manufacturer Redacted text have invested heavily, developing product and supporting the local and international weighing industry for more than 25 years.

4.2.5.c.
Efficiencies come when an arrangement can be measured first and monitored. Currently without mandatory re-verification periods there is little ongoing monitoring, that can be legally exerted.
Additionally provide NMI greater resources in areas such as Pattern Approvals which can cause delays in getting product to market in a timely manner.

2.1.1.
As a Manufacturer the cost of the Pattern Approval process is an accepted cost to business if we wish to produce units that are used in Trade applications. That is to say we do expect a cost in this process but don't necessarily agree with the cost amounts.

2.2.1.
It does strike balance as all in the supply chain have a common point of reference.

2.2.2.
Measuring instruments use for Trade purposes should obviously apply, but it should also be extended to and include areas where there is risk of injury, death and / or litigation. Areas such Maritime, Pharmaceutical, Environmental, health and wellbeing are all areas that should be inclusions.

2.3.1.
Flexibility may be introduced by working more closely with the developers of newer technologies to gain a true understanding of the benefits of such technology weighed against the risks of rapid uptake. There will be areas where the risk of rapid uptake may have minimal impact and others where the risk is far greater, so risk assessment should be a consideration to provide some flexibility in areas of low risk. Flexibility could be incorporated within the Pattern Approval of the instrument after thorough testing by NMI.

2.3.2.
With regards to Weighing, introduction of mandatory re-verification periods would ensure the constitutional rights of all Australians in equity of trade over prolonged periods of a devices in-service usage. Currently there is no legislation that requires a weighing device to be reverified ever again after it is initially verified unless it has been repaired, altered or adjusted other than Public Weighbridges. What this means is that there many many weighing devices that are not periodically checked to verify they are actually still accurate within tolerances after a prolonged period of time. Introducing mandatory re-verification periods will allow an external audit of the instrument and provide consumer confidence. At present the responsibility lies with the instrument owner to ensure their instrument maintains weighing accuracy without external audit. In the vast majority of cases instrument owners are not qualified and do not have the means to ensure the instrument is weighing within Maximum Permissible Error
(MPE) as required by Law

3.1.1.
There has been times of delay to receive approval on equipment due to the lack of resources at NMI. This causes delays in getting product to market impacting financially. Additional resources in NMI pattern approval would help reduce time delays.

4.4.1.
Yes, the process of verification and certification provide bench marks that must be met and in doing so all devices used in trade need to comply with the same requirements, this also levels the playing field of competition in the market place. Mandatory re-verification periods would be further effective providing confidence that the initial verification and certification accuracy is maintained.

4.4.2.
Yes, in particular weighing instruments used for trade should all be under mandatory re-verification periods. There are measuring instruments in use today that have never been re-verified after their initial verification and certification after many years of in-service use. The risk is there is no legislation that requires a weight measuring devise to be re-verified ever unless it is repaired, altered or adjusted (other than Public Weighbridges). The question should be asked as to why Public Weighbridges do have mandatory re-verification periods while other weighing devices used in trade do not. Weighing instruments are sensitive devices and subjected to physical forces, they can be outside of Maximum Permissible Error (MPE required by Law) by the act of relocation or overloading the the weight range of the instrument.

4.4.3.
Yes, as a Manufacturer the current framework serves to enable the production of weighing indicators (primarily) to be sold into trade applications. To better meet the needs of the community there needs to be confidence that transaction integrity is maintained over prolonged periods, mandatory re-verification periods would ensure that all instruments used for trade are externally audited and still compliant with MPE (Maximum Permissible Error) and other areas as required under the framework.

2.1.1.
Delays in pattern approval processes delaying product getting to market in a timely manor. Increases in pattern approval costs that out strip reasonable expectation and place additional costs on the business making for a less competitive edge in the local market.

2.1.2.
Better communication between the government and instrument owners of their obligations. Introduction of mandatory re-verification periods to ensure all instruments for transactions maintain accuracy over prolonged periods and are externally audited to ensure they still meet MPE (Maximum Permissible Errors).

4.2.1..
Weight based transactions should use weighing instruments that are fit for purpose as the principle reference to ensure correct measurement and whereby provide confidence in the market place.

5.2.1.
The current approach is acceptable and gives clear guidance on what is required.

5.2.2.
Weight statement is very important to determine the quantity of the contents of a package in order to compare value for money.

6.3.1.
The current system has evolved over time to meet change with the introduction of AQS (Average Quantity System). Trade Approved Check Weighers may be an option in areas where the current methods are not adequate.