Response 613788581

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Your details

Name and contact details

Name
Tom Gordon

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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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Yes Ticked No Unsure
Supporting industry development and technology innovation
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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
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Not important Somewhat important Ticked Highly important Unsure
Facilitating a level playing field for business
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Not important Ticked Somewhat important Highly important Unsure
Consumer (or the broader term customer) protection
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Ticked Not important Somewhat important Highly important Unsure
Supporting industry development and technology innovation
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Further comments

Further comments policy objectives
In this submission, I, Tom Gordon, am representing as a member of the Science Party. This submission is not on behalf of the Science Party. The Science Party’s principles include an evidence-based approach to policy making and we believe that a strong focus on evidence and logical reasoning in policy discussions will make a stronger policy platform and a stronger economy. The Science Party is happy to submit some suggestions to the Legal Metrology Policy Review discussion paper. Facilitating a level playing field for business - In addition to policy objectives for business, we believe there is a strong case to have clear policy objectives for science research. As science and innovation are, in some areas, becoming more connected and commercialised, the nexus between business and science should be addressed. The Chief Metrologist, we argue, must have strong links with both the Minister for Science and Research as well as the Minister for Innovation and Industry that we have proposed in our policy platform. The level playing field is created by the in-depth and outstanding science and research carried out by the NMI. Consumer (or the broader term customer) protection - We don't think it is necessary for NMI legal metrology to protect the consumer. The NMI’s role is to focus on physical and legal traceability, not protect customers. Customers are indeed protected by the regulations and objectives of legal metrology but this should be covered by consumer regulations supported by legal metrology, not part of the legal metrology framework. We think that this would be a duplication of legislation and therefore could be poor use of resources. Supporting industry development and technology innovation The Science Party strongly encourages supporting industry development and technology innovation, especially in the following areas: - Space - Driverless cars - Renewable energy and storage It is Science Party Space policy to: Establish an Australian Government Space Agency: ASTRA (Australian Space Technology & Research Agency) and accept the invitation from the European Space Agency to become an associate member; and Introduce regulations that encourage the building and development of space infrastructure in Australia; and Undertake a Space Innovation and Growth Strategy Study. Since there is no existing unified Australian space industry,the industry, its technology and its regulatory framework will develop rapidly, and will need support from a physical and legal metrology standpoint. The Science Party believes that driverless cars, trucks and public transportation should be legalised in Australia as part of a testing program, with aims to introduce driverless cars as regular items on the road as soon as is practical and safe. Driverless cars have the potential to reduce collisions and hence cut road related mortality. Driverless cars can also drive more efficiently, find quicker routes, prevent intoxicated driving, and increase the mobility of people who cannot drive due to disability or age. Most of these policy elements have direct implications on the legal and physical metrology, such as reconsiderations of breath testing and speed enforcement. The NMI will need to support our energy sector as it will (ideally) change quickly and substantially, as we reduce our reliance on fossil fuels and face . This will include regulations with smart meters, modernising our grids and the implementation of emissions trading schemes, all of which have direct connections with legal and physical traceability.

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
What should be the criteria for Australia’s participation in the development of - international documentary standards relevant to legal metrology? - Just as Australia contributes to the international standards in physical metrology, so should we contribute to international standards for legal metrology. International collaboration is an essential part of international standards, and Australia national institute needs to be a major part of this. Our criteria should be if Australia has a part to play in a particular standard, or we rely on a standard in our measurement system, then we should contribute to international standards. As outlined earlier, Australia should also take a lead role in technology and innovation, especially in areas that will need some further development of legal metrology standards.

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

Further comments
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Principles-based approach to regulation

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

Key principles
The Science Party believes that the best regulatory approach is good regulation, not lots of regulation. This should be applied to Legal metrology also.

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
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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
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What should be the legislative status of such guidance material?

Source of guidance material
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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
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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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Not important
Somewhat important
Ticked Highly important
Unsure
Further comments
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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
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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
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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
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What are the appropriate circumstances for NMI to consider referral for prosecution as a regulatory response?

Appropriate circumstances for prosecution
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Further information

Further comments

Further comments
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