Response 21578610

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Privacy Collection Statement

Do you agree to the Privacy Collection Statement?

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(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
JP Van Loenhout

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
Ticked 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
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
Ticked 5-19
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
Ticked 51-100
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 Somewhat important Ticked 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 Ticked Somewhat important Highly important Unsure

Further comments

Further comments policy objectives
A requirement for consequences to be upheld when 'consumers/customers' are being unfairly and unknowingly taken advantage of by businesses that disregard the importance of verifying measuring equipment.

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
International standards are set at various levels to Australia. We should be working together with international standards to develop a base line set of standards that are fair for everyone.

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
NMI should be aligning with International Standards within reason and working cooperatively with these organisations to develop standards that suit Australian working conditions and marketplace.

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

Further comments
Fair review of Australian working conditions should be taken into account, an intelligent / common sense approach is required without risking safety for consumers, companies and business owners.

Principles-based approach to regulation

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

Key principles
- Safety - Fairness - Strong leadership and Strict consequences.

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
As for any business, the cost for maintaining compliance in a tight marketplace.

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
Australian Standard

What should be the legislative status of such guidance material?

Source of guidance material
Australian Standard

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
Extent of time between verification, reported breaches etc. can make up / set the priority levels. A form on online compliance audit system to upload all clients into NMI data base and track conformance.

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

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

Focus of regulatory activity in relation to conformity
Develop standardised forms/documentation for all to utilise and submit. Allow companies and business to carry out site audits and submit direct to NMI. Then allow NMI to focus on priority issues with pending actions to give site owners and operators time to improve their operations.

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
Concentrate on building formal, legal and standard audit tool, allow findings to filter back from verifiers. Take action/follow ups on known operators who breach current standards.

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
NMI must take the findings from verifiers, then must make their own investigation before allowing the operators a set period? 3 months etc. to complete improvements.

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

Appropriate circumstances for prosecution
If an operator refuses to comply after a set period.