Response 183758798

Back to Response listing

Privacy Collection Statement

Do you agree to the Privacy Collection Statement?

Please select one item
(Required)
Ticked Yes, I agree
Yes, I agree and would like to make a confidential submission
No, I do not agree

Your details

Name and contact details

Name
Jason Ferguson

I am submitting on behalf of

Submission for
Please select one item
Myself
Ticked Business
Consumer association
Government department/agency
Industry association

Industry information - Business

Your industry

ANZSIC: div_name
Please select one item
Agriculture, Forestry and Fishing
Mining
Manufacturing
Electricity, Gas, Water and Waste Services
Construction
Wholesale Trade
Retail Trade
Accommodation and Food Services
Transport, Postal and Warehousing
Information Media and Telecommunications
Financial and Insurance Services
Rental, Hiring and Real Estate Services
Ticked Professional, Scientific and Technical Services
Administrative and Support Services
Public Administration and Safety
Education and Training
Health Care and Social Assistance
Arts and Recreation Services
Other Services

Type of business

Type of business
Please select one item
Ticked Servicing licensee (verifier)
Legal metrology authority
Measuring instrument supplier/distributor
Measuring instrument user
Other

Number of Employees

Number of Employees
Please select one item
0-4
5-19
Ticked 20-199
200+

How many measuring instruments does your business interact with per year? (e.g. used/sold/verified)

Number trade instruments
Please select one item
1-10
11-50
51-100
Ticked 100+

Submission process

How would you like to submit your response

Please select one item
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
Please select one item
Ticked Yes No Unsure
Facilitating a level playing field for business
Please select one item
Ticked Yes No Unsure
Consumer (or the broader term customer) protection
Please select one item
Ticked Yes No Unsure
Supporting industry development and technology innovation
Please select one item
Ticked Yes No Unsure

What is the relative importance of the following policy objectives for legal metrology in Australia?

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

Further comments

Further comments policy objectives
The legal metrology system is there to ensure that business and consumers are trading legally and fairly, this can only be done with a system in place that ensures the quality and accuracy of the equipment and the operation thereof.

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
It should be a requirement of fixed period verification of equipment. This will ensure that businesses with trade approved equipment are having it tested at suitable intervals.

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
Australia's NMI is currently recognised as being one of the top metrology governing bodies. Therefore NMI should be actively involved in the development of standards relevant to legal metrology.

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
OIML standards should be followed as these are the metrology standards, they should be developed to reflect current technology.

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

Further comments
Flexibility should be minimal, and must be supportedby field trials. Too much flexibility will weaken the integrity of NMI.

Principles-based approach to regulation

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

Key principles
- accurate, repeatable equipment and processes. The current system has the regulations that is required. There are areas of improvement, greater resources for motioning and enforcing the regulations, pattern approval

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
zero

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
Business and consumers need to be made more aware of the regulations, the impacts and benefits. Online advice is sufficient, but needs to be easily accessed and and explained in layman's terms.

What should be the legislative status of such guidance material?

Source of guidance material
It should be expressed as advise giving businesses the ability too learn what is required to be done without fear of prosecution. This allows them to take the necessary actions to comply.

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
Ensure that trade approved equipment is used fro trade activities, and that the equipment is maintained and checked regularly by an external body.

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?

Please select one item
Not important
Somewhat important
Ticked Highly important
Unsure
Further comments
Items requirements, policies should be fit for purpose as well as complying with the required NMI regulations

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

Focus of regulatory activity in relation to conformity
NMI, should increase the checking of equipment, this should be done by focusing on specific industry groups. Educating them on their requirements to meet the regulations.

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
As per previous by addressing specific industries, that have known issues. NMI could become active in talking to group associations.

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
An education, warning, financial penalty process should be followed. Education is required, because a lot of the regulations are hard to find and difficult to understand for the layman.

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

Appropriate circumstances for prosecution
When education and warnings have been ignored. Or when the regulations have been blatantly ignored.

Further information

Further comments

Further comments
The questions in the review are poorly worded, and are quite difficult to understand. They should be written clearer. The true intent of the review should be made known.