Response 813649074

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Privacy Collection Statement

Do you agree to the Privacy Collection Statement?

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Ticked Yes, I agree
Yes, I agree and would like to make a confidential submission
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Your details

Name and contact details

Name
Paul Mason

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
Agriculture, Forestry and Fishing
Mining
Ticked 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
Servicing licensee (verifier)
Legal metrology authority
Measuring instrument supplier/distributor
Ticked Measuring instrument user
Other

Number of Employees

Number of Employees
Please select one item
0-4
5-19
Ticked 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
Ticked 11-50
51-100
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 Ticked Somewhat important Highly important Unsure

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
As the world trade market grows, It is imperative that we have a unified system that can be replicated in any arena where measurement is required.

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
To find a system that in the majority works for all. World trade standards should be the driving force to achieve a relevant and useable system

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

Further comments
Should be based on industry needs not individual wants

Principles-based approach to regulation

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

Key principles
consistency, repeatability and accuracy

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
Standard operating procedures

What should be the legislative status of such guidance material?

Source of guidance material
Legally enforceable

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
Further comments
No good having a system that is not easily implemented and adds relevance to the process

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

Focus of regulatory activity in relation to conformity
Ensuring that regular calibrations of all measuring equipment is done

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, as they do now

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
Repeat offenders should be penalized, sliding scale approach required

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

Appropriate circumstances for prosecution
Where a party has knowingly allowed a breach to occur for financial gain