Response 950227777

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Privacy Collection Statement

Do you agree to the Privacy Collection Statement?

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Yes, I agree and would like to make a confidential submission
No, I do not agree

Your details

Name and contact details

Name
Steve Schubert

I am submitting on behalf of

Submission for
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Ticked Myself
Business
Consumer association
Government department/agency
Industry association

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
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Ticked Yes No Unsure
Consumer (or the broader term customer) protection
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Ticked Yes 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
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
31/8/2016 I request for the results of this survey be made available to me immediately via E mail.

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
Public announcements as to investigations & findings submitted to the general public by the appropriate media including hard copies in newspaper format. Total transparency of results of investigations including time, locations, offending identities (names of companies registered & trading as) under investigation being disclosed.

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
Total public disclosure & transparency of all procedures.

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

Further comments
Total public disclosure & transparency of all procedures.

Principles-based approach to regulation

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

Key principles
Transparent honesty for the Australian consumers via public media.

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
Total disclosure of all principles used in compliance.

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
Sufficient to enable full understanding with a list of penalties for misconduct.

What should be the legislative status of such guidance material?

Source of guidance material
Comprehensive guidelines available to all participating parties including full, accurate public disclose.

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
Transparency of priorities of regulation, compliance & enforcement through public disclosure via all media outlets available for the Australian public.

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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Ticked Not important
Somewhat important
Highly important
Unsure
Further comments
Full public disclosure via all media outlets available for the Australia consumers & public in general.

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

Focus of regulatory activity in relation to conformity
Setting firm but legal & easily understood guidelines for all participating entities with clear, concise instructions as to penalties for non-conformance. Utilising public disclosure for all activities of actions for compliance & non-compliance of all entities.

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
By full, transparent disclosure of all breaches of compliance including penalties utilised, entities named with dates in a public forum as available to the general public. Utilising the Australian legal system - again with conduct, results available for public scrutiny.

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
Full disclosure for the Australian consumers to decide themselves for future patronisation as well as increased penalties for continued non-compliance.

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

Appropriate circumstances for prosecution
Simply: If regulations are clear & comprehensive which includes all penalties for breaches of conduct: then referral is mandatory. Public disclosure is also mandatory.

Further information

Further comments

Further comments
Full consideration of the importance of the Australian consumer is tantamount for protection, over & above any Government institution which is answerable to the Australian judicial system.