Response 538508518

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Your details

Name and contact details

Name
Reece Godfrey

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Business
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Submission process

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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
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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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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
Provided the international documentary standards are comparable with Australia, I don't see any problem.

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
Currently the protection of Trade Measurement by NMI is sufficient, without over protection and "Red Tape".

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

Further comments
NMI should look at outcomes from ISO & IEC and be used in conjunction with the current OIML standards when considering a pattern approval of an instrument to be used in Australia.

Principles-based approach to regulation

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

Key principles
A fair and accurate measurement system that provides confidence for both business and the consumer but still allowing consumer protection against fraud and unfair competition.

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
I feel that under a principals based regulatory environment the law becomes weaker as there is chance that business & industry may bend the rules to their advantage.

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
Easy to read, common sense Fact sheets.

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
Currently NMI's Compliance and Enforcement Policy, although can be interpreted by some as having gaps and "Grey Areas". The basis of the law is like the applied tolerances on weighing equipment, that it is black and white, the instrument like the law is either correct or incorrect.

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

Focus of regulatory activity in relation to conformity
To ensure compliance by business by doing regular audits.

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
Provide education to business as to trade measurement requirements, do inspections and audits.

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
A notification of Non-Compliance and after a follow up visit if these issues are not corrected then financial penalties should be imposed. Of course, common sense should also be used as to the severity of the Non-Compliance.

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

Appropriate circumstances for prosecution
Continued refusal to comply with Trade Measurement Law and or blatant fraudulent activity.