Response 258693464

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
Ian Ruxton

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
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
Ticked 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
Ticked 0-4
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
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 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
Mandatory periods to have instruments verified. Eg 24 months Spirit Dispensers

Principles-based approach to regulation

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

Key principles
Consistancy.

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
Lack of knowledge of their statutory obligations.

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
Guidance material to be clear, straight to the point, & written in layman's terms. They should be made aware of when instruments are required, type required. What type is legal for that purpose, & how often they are to be verified.

What should be the legislative status of such guidance material?

Source of guidance material
Binding

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
Same as per Guidance material.

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
Common Sense approach

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
Bring in time periods for re verification. eg, 24 months for Spirit Dispensers.

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
In my field i would suggest a period of 2-3 weeks to rectify any breaches. 99.9% of in-discrepancies are unknown & of no fault of the vendor. All the more reason to implement re-verification time periods. Failure to comply to any rectification or failure to re-verify within time restriction should be fined per unit after one only warning.

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

Appropriate circumstances for prosecution
Serial offenders, vendors with blatant disregard for any regulations & vendors who fail to comply after a warning should be prosecuted.

Further information

Further comments

Further comments
From a personal view. In NSW & ACT when the dept of Fair Trading was in control of trade measurement, a re-verification period of 24 months was in place my business was viable. Now however with re-verification being de-regulated my business is floundering. I have been forced to take on a part time job & will most probably not renew my servicing license next year. I have enjoyed doing it & i believe I did it well but economics say Stop. I have doubled my marketing program & expanded my area covered but all to no avail. My colleagues in the same field are also in the same plight.