Response 441585496

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Name
Gary Peers

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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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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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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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Further comments

Further comments policy objectives
The field officers should be undertaking more inspections of measuring equipment as there are a lot of items in the field that go without registration for years at a time.

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
Better education and information for business owners regarding their obligations for testing of equipment they own or purchase.

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
There should be a national and international standard as some imported equipment may have differing allowances for their measurement testing.

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
Australia should work to which ever of the standards gives the minimum tolerances of allowable difference to the measurement amount.

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

Further comments
There should be little to no flexibility as a standard is a standard.

Principles-based approach to regulation

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

Key principles
Ensuring that the different industries and workplaces have ample knowledge of the rules and regulations.

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
There should be no concern if everyone using equipment in an industry have to abide by the standard that is given, more education and inspection is required.

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
The guidance material should be easy to read, understand and comprehend. This material should be made available to all industry and workplaces and be part of the training of the users of this equipment.

What should be the legislative status of such guidance material?

Source of guidance material
The legislative status should be federal and state.

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
Education and training for all types of industry and workplace, field officers need to be supporting the servicing licence holders and having them work with the indiviual owners and operators of this equipment.

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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Further comments
Items coming into the market that protect the consumer should be a high priority.

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

Focus of regulatory activity in relation to conformity
Look at increasing the number of field officers and also work with industry associations to ensure their members understand what compliance is.

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
Increase the number of field officers and have industry specific compliance officers.

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
Contact the servicing licencees and have them visit the offending business and try to help the business work through their issue.

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

Appropriate circumstances for prosecution
Continued disobedience in relation to the act.

Further information

Further comments

Further comments
There should be more interaction and meeting with the servicing licencees to ensure that the latest items coming through testing and approval are shown to us. This would allow feedback to the business owners and customers of the servicing licencees. Definitely a once a year workshop held in the major city locations for each of the different industry groups.