Response 798211778

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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
Eric Wake

I am submitting on behalf of

Submission for
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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
Ticked 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

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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

Further comments

Further comments policy objectives
That the controlling sector of this organisation needs to get its act together. 1. the time that scale calibrations are seen to be accepted as correct from time of certified/with certificate 6 attached are able to be used. 2. make it clear to a person trading in weights and measures in their business that they are responsible for the maintenance and accuracy of their unit from day 1 that they trade. 3 Change the length of time a certificate is current..... ie 1 year thru to 3 years... i suggest 2 years. 4 Change of compliance stickers/label and the information that is written on them to include date in plain english not code...as it is now.

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
AS ABOVE.. A. More information that is handed out by re-sellers and repairers that has certificate attached to it this booklet shall make people aware of the reason for scales and correct measuring but also the need for them to be responsible in care and upkeep to your standards. B Every licensee should have a photo ID tag or card to be on them when working with products. Supplied at nominal cost of $20 by the dept. C. if you are continuing the use of the current stickers then what you say shall be implemented properly by every licensee on every sticker. IE: only one sticker per device, that shall have been stamped details on by metal punch is what the current regulation says by your letter. but some re put on blank, some are put on with "sharpie" black writing .............. no standard is being maintained, D. for the protection of ALL PARTIES make it that weights and measures shall be tested EVERY 2 YEARS. note well that you require the Licensees to have their masses up to date every 2 years or a fixed time interval SO why is the consumers devices any different??? E. that the department abide by Govt rules: invoice a customer then expect payment then issue a receipt........ and not request an amount be paid for license by email then send as being paid a invoice marked paid.... as now the case. F. SUPPORT The LICENCEES WHO SHALL SUPPORT YOU. Support is not happening, and you are loosing the licencees to other trades because of the way you are running or NOT running the operations.

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
I think only you can answer this being "Johnny on the spot"

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
see above

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

Further comments
Consideration of different patterns to what we have is a plus

Principles-based approach to regulation

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

Key principles
1. Create a team that is all of the one page and together as a family...... not dismembered as it is now. 2. Make it easier for the end user to know whats is happening. 3. Bring back 2 years recal and issue of certificates 6

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
Their lack of knowledge.... due to there not being a resellers welcome to trading by weight an measure package for them

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
A pack should be available for re sellers to hand out with scale enquiries.and mandatory that a pack be given to all new certification with the certificate 6 inside

What should be the legislative status of such guidance material?

Source of guidance material
a. history of why it is necessary b. examples of the right scale for the job and how a chocolate shop went broke in 12 months because they were buying their chocolates in from the supplier on a scale e being .01gm and re bagging their chocolates into bags by a scale weighting e of 15gm's... and the cohocolate was $40 a kilo. c. how the appliance should be sited and level d. clearly your contact details.

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
A smile

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
Specialised units for special purposes yes..!

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

Focus of regulatory activity in relation to conformity
Be fair to both parties, listen....listen.... listenup

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
1. create a team of persons who look after licencees in each state...NOT ALL OVER THE PLACE AS IT IS NOW .... 2. listen to what licencees say. 3. take your head out of the sand ... 4. make more information available to end users

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
Penalties are for HOON Drivers burning rubber or driving using Phones. If a person continues to disobey orders impound his weights and tickets cross him off the register and fined him too !

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

Appropriate circumstances for prosecution
a. Fraudulant actions b. Continuing to disobey orders

Further information

Further comments

Further comments
You will get many items of reply to your request for information. PLEASE MAKE SURE THAT IT IS USED WISELY AND NOT JUST FILED INTO SOME SLOT IN SOME COMPUTURE or into the IN tray of the lady who is on 6 months maternity leave. PLEASE CONTACT ALL THE RESPONDANTS BY PHONE OR MAIL just as a courtesy because we spent 30 minutes of our life on earth trying to help you. Have you not realised that while you are the controller of your laws you make WE the Licencees are the Police in the Fields implementing and being penalised to do so......... You should be subsidising the cost of licensing and up keep of measure tools because we are the ones doing the work for you>>>>>>>>>>> MAKING SURE that your Policies are implemented our phone is 0898 412212