Response 492230016

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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
Justin Macdonald

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
Ticked 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
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 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 Somewhat important Ticked 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
International trade harmonisation, confidence in the results relating to Australian grain shipments

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
Method standardisation Agreed accuracy levels

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 needs to recognise ISO accreditations in some way particularly for ISO accredited licensees

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 considered for organisations with accredited quality systems, otherwise - no

Principles-based approach to regulation

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

Key principles
Equity and accuracy

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
Awareness of the requirements that apply to them

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
The factors would be the results of compliance audits to determine the level of compliance and tan understanding of the risks associated with non compliance

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
Generally speaking the larger ISO accredited business's have a good understanding of risk and compliance, and so regulatory focus is probably un-necessary. The focus of regulatiry activity should be for the non-accredited smaller businesses who are unlikely to be aware of the compliance rules that apply to them.

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
Audits and site visits

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
Low weight to initial warnings, more weight to subsequent breaches

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

Appropriate circumstances for prosecution
Tampering with marked instruments. Systematic and deliberate bias away from zero to the advantage of the business

Further information

Further comments

Further comments
NMI should consider utilising the existing network of servicing licensees as NMI approved "Compliance consultants" for business. Where a business can become aware of the compliance requirements that relate to it, get a compliance perscription for the whole of their business, rather than having to become aware of the individual class requirements from individual servicing licensees. Perhaps some NMI training for ISO accredited licensees to create this group of consultants. Existing licensees do a lot of this informally anyway. I see an opportunity to create a bridge mechanism here for businesses to engage with their regulatory requirements, without having to confess to existing non compliance.