Response 1009448237

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Your details

Name and contact details

Name
Lisa Simpson

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Submission for
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Business
Consumer association
Government department/agency
Industry association

Submission process

How would you like to submit your response

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Ticked Through the online survey
Emailing a confidential response

Policy objectives for legal metrology in Australia

Are the following policy objectives appropriate for legal metrology in Australia?

Supporting confidence in the measurement system
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Ticked Yes No Unsure
Facilitating a level playing field for business
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Consumer (or the broader term customer) protection
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Supporting industry development and technology innovation
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What is the relative importance of the following policy objectives for legal metrology in Australia?

Supporting confidence in the measurement system
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Not important Somewhat important Ticked Highly important Unsure
Facilitating a level playing field for business
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Not important Somewhat important Ticked Highly important Unsure
Consumer (or the broader term customer) protection
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Not important Somewhat important Ticked Highly important Unsure
Supporting industry development and technology innovation
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Not important Ticked Somewhat important Highly important Unsure

Are there any other policy objectives for legal metrology that would assist in delivering successful outcomes for Australian businesses and consumer?

Any other policy ogjectives
Education of the public about the services provided

International cooperation and harmonisation

What should be the criteria for Australia's participation in the development of international documentary standards relevant to legal metrology?

Your response on criteria for Australia's participation in international standards
A definition of success prior to engaging in the process. Educate other countries. Obtain information on best practice from the international community.

What should be NMI’s approach to determining Australia’s pattern approval requirements where documentary standards from organisations such as the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) more fully account for recent developments in technology and operation of measuring instruments than equivalent OIML standards?

NMI's approach to pattern approval requirements
Link in to the higher level standards - on the proviso that the interests of Australian citizens and businesses / industries are protected

To what extent should NMI consider flexibility to allow for particular circumstances in Australia when adopting international standards for pattern approval?

Further comments
A clause detailing items specific to Australia

Principles-based approach to regulation

What are the key principles that should drive Australia’s regulatory approach to legal metrology?

Key principles
Fairness Accuracy Education

What concerns, if any, could there be for a business when managing compliance in a principles-based regulatory environment?

Business concerns managing compliance in principles-based envirnment
Misinterpretation of compliance requirements Time and cost Equipment maintenance Currency of education

What level of guidance material, if any, should be available to ensure stakeholders have sufficient understanding of the policy objectives and outcomes being sought?

Level of guidance material
Online access

What should be the legislative status of such guidance material?

Source of guidance material
No comment

Risk-based approach to compliance monitoring

What are the appropriate factors to inform risk management related to setting priorities for regulation of legal metrology, including compliance and enforcement activity?

Factors to inform risk management
Key stakeholder analysis that is in laymans terms.

Regulatory approaches for legal metrology - Fit for purpose

How important is it that NMI considers the broader context of 'fit-for-purpose' when developing requirements/policies in relation to measurement?

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Not important
Somewhat important
Ticked Highly important
Unsure
Further comments
Otherwise it would be a waste of time and effort

How should NMI focus its regulatory activity in relation to conformity to type assessment?

Focus of regulatory activity in relation to conformity
Education, education and education!

Regulatory approaches for legal metrology - Compliance and enforcement

How should NMI focus its compliance activities to ensure businesses are meeting their obligations under trade measurement law?

Comments-NMI focus of compliance activities
Collaborative improvement (warnings, support to address rather than risking fines)

What relative weight should NMI give to: identifying that certain thresholds have been breached; and individual risk assessments, before financial penalties are imposed?

Comments-relative weight
7/10

What are the appropriate circumstances for NMI to consider referral for prosecution as a regulatory response?

Appropriate circumstances for prosecution
Intentional and deliberate non compliance, 3rd time warning