Response 148534899

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Introduction

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Name:
David Finlay

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Trang Imagineering

Current regulatory framework

4.1. What should be the role of Australia’s measurement laws in a modern economy?

What should be the role of Australia’s measurement laws in a modern economy?
To manage, standardise, and control measurement laws, and to cause unauthorised units to be ceased.

Measurement laws in other countries

5.1. What should be within the scope of Australia's measurement laws?

What is the appropriate scope of Australia measurement laws?
Identify Key units of measurement that should be adhered to. Identify 'Grey' areas of units that can be used within guidelines. Identify Non-Use units of measure that should be ceased.

5.2. Are there ways in which the current scope of Australia’s measurement laws could be expanded or limited?

Are there ways in which the scope of Australia’s measurement laws should be limited?
I think it is best that the measurements laws stay contained to a specific scope.

Principles-based legislation

6.1. Would you be confident of operating in a principles-based regulatory environment for measurement? Why or why not?

Would you be confident of operating in regulatory environment for measurement that is characterised by principles-based legislation? Why?
Perhaps, but some of this may also be considered a "Tolerance". It is probably best that the legislation remains, but provides tools for external submissions when an item needs to be outside of the laws.

6.2. Would the need for detailed guidance material limit the value and flexibility of a principles-based approach to measurement laws?

Would an implemented principles-based approach acquire such a quantity of additional guidance and specification that the value of the principle-based approach was neutralised?
Detailed guidance would be advantageous, as long as it works in association with relevant industry standards.

Measurements used for trade

7.1. Are there benefits from directly regulating an area of measurement as opposed to providing broad principles of good measurement practice without direct intervention?

Are there benefits from directly regulating an area of measurement as opposed to providing broad principles of good measurement practice without direct intervention?
Not always. Some methods of measurements are based on a range of factors such as Mass and Volume of granular products, that are established industry systems. Perhaps it is best that these standards are researched and documented as future guidelines.

7.2. What regulatory models should Australia’s measurement laws enable (for instance, principles-based, compliance-focused and/or rules-based), and why?

What regulatory models should Australia’s measurement laws enable (for instance, principles-based, compliance-focused and/or rules-based), and why?
It needs to have defined measurement 'standards' and if there is a non-compliance, then the non-compliance must be due to either: - blatant dis-regard for the standard - a tolerance issue that needs to be addressed - a new measurement 'instrument' that needs to be considered to be added to the standard

Changing nature of trade measurement

7.1.1. What types of measuring instruments should be regulated by Australia’s measurement laws?

What types of measuring instruments should be regulated by Australia’s measurement laws?
Not sure that the laws need to encompass specifics such as: protein content per tonne I think this is too broad of a measure for laws to include. The laws need to keep focus on specific areas such as: the measurement of protein, and the measurement of a tonnage. There would be thousands of examples of other similar ratios: - grams of minerals per tonne of mined ore - joules of energy per tonne of coal

7.1.2. How should Australia’s measurement laws apply to transactions for goods and services that are based on measurement?

How should Australia’s measurement laws apply to transactions for goods and services that are based on measurement?
They need to be specific enough that comparisons of items can be compared without imposing on the product itself: Examples: Land: Marketed as both Acres or Hectares whereby in both situations, the physical size of the land is identical. Steel Bar: a 50mm steel bar is just that. It would have a tolerance on the product, but in effect it would measure 50mm. If however, the bar needed to suit an Imperial size, it could be marketed as either 2" or 50.4mm, which is compliant. Imperial Bolts: a 3/4" UNC nut is what it is. It is a standard. It is not a metric standard, but it must be acknowledged. Subway: A 'Foot Long' or 'Six Inch' sandwich are in effect nicknames that infer the size of the product. I feel that this is a poor use of measurement that is arguably non-compliant, and unnecessary.

7.1.3. What regulatory models should be applied to quality and quantity measurements?

What regulatory models should be applied to quality and quantity measurements?
I think it is best, that regulatory measurements stick with the core measurement units, and their relevant tolerances. The ratios of these need to be determined by industry. Perhaps there is an opportunity to include a Tolerance Class for some products (such as protein/tonne grain), but most industries already have an established system for determining these ratios.

Exemptions

7.2.1. How should Australia’s measurement laws specify the types of measuring instruments they apply to? For instance, by exemption or inclusion requirements?

How should Australia’s measurement laws specify the types of measuring instruments they apply to? For instance, by exemption or inclusion requirements?
I feel that some units, such as 32 Inch Display TV, are arguably out of date in todays measurement systems, and should be looked at being phased out. They are not deceptive, but are an obsolete method of measurement. I feel that exceptions should be made very limited, and difficult to obtain. Gas Heater: Joules energy / litre gas Phone: units based upon time, or bytes of data Taxi Fares: units based upon time, or by distance I find it difficult that all measurements cant be based upon simple SI units, or ratios of SI units.

7.2.2. What are your views on the current listed exemptions?

How are the current listed exemptions not appropriate?
I think it is unfortunate that this is happening. They should be reviewed, and standardised on comparative established units.

Non-trade measurements

8.1. What future measurement needs or priorities would benefit from a measurement framework?

What future measurement needs or priorities would benefit from a measurement framework?
I think that if there needs to be some flexibility in the system, then it needs to have an identified system of preference. - Preferred measurement method - Alternate measurement method A, (BCD etc) It must also identify any measurement methods that may be being used, and are to be ceased being used. I.e: Acres of Land

8.2. Should the focus of the Australia’s measurement laws be to regulate measuring instruments or measurement results, or both?

Should the focus of the Australia’s measurement laws be to regulate measuring instruments or measurement results, or both?
Not the results. That is for industry to determine. Perhaps it should include acceptable tolerances, but mostly it should focus of the System.

8.3. How should the national measurement framework apply to non-trade measurements and instruments? Should the approach be different for different types and/or categories of measurement?

How should the national measurement framework apply to non-trade measurements and instruments? Should the approach be different for different types and/or categories of measurement?
In these cases it should make reference to the basic system (i.e. Length is to be SI Metres), and then refer to the relevant Australian/ISO Standard. There is no need to double-up on such specifics.

8.4. What are the types of non-trade measurements (and measuring instruments) that would benefit from inclusion within the measurement framework?

What are the types of non-trade measurements (and measuring instruments) that would benefit from inclusion within the measurement framework?
Perhaps just the confirmation of what existing standards are acknowledged as being acceptable, and which ones are non-acceptable.

8.5. Are there instances in which non-trade measurements (and measuring instruments) requires a nationally consistent approach to measurement?

Are there instances in which non-trade measurements (and measuring instruments) requires a nationally consistent approach to measurement?
(besides railway gauges?)