Scope of Australia's Measurement Laws

The Role should be to maintain the integrity of a measurement system that is recognised both domestically and internationally.
• The role should still be largely the same as it has always been.
• A framework is required to ensure fair trading of goods and commodities.
• Actively enforce accurate weights and measures transactions to provide protection and to ensure accurate delivery and pricing of goods traded, via Trade Measurement Inspectors.
• Ensure integrity of measuring instruments which conform to local requirements.
• Protection of both customers and suppliers as the cornerstone of Business confidence.

Any device or process that underpins a financial transaction or would put the public at risk of death or serious injury through incorrect measurement, or in cases where measurement may form the basis of a legal case in the criminal or civil courts. The Scope should encompass areas discerning measurement in all facets, whether it uses trade approved or non-approved systems it still should be under the protection of Australia's Measurement Law to protect consumers, businesses, health and wellbeing of the Australian public.

• Measuring instruments would include examples such as; Scales, Petrol pumps, Electricity meters, Water meters, Phone, Data meters, etc.
• Industries reliant on measurement would include examples such as; Pharmaceutical, Transport, Maritime / SOLAS, Retail Trade, Worksite Safety, Law Enforcement etc.

We understand the need to be flexible in a changing environment but the adherence to quality in process and outcome is paramount to Australian businesses. A majority of our members are not confident on principles based regulatory environment for measurement.

• A principle based regulatory environment would be relying on our honesty, approach and experience to providing good measurement practice. We are comfortable with the current system as specific
guidance determines what “are the limits”.
• We understand principles Based regulatory environment may fuel innovation, but we are satisfied with the current Act, Regulations and OIML standards. This currently falls under a prescribed method and works in most scenarios. On occasions where the prescribed method does not keep up with changes, this is covered off at the point of local Australian pattern approval, as is the current process.
• The issue with Principals Based is that it is open to even more interpretation especially if contested in a Court of Law whereas Prescriptive Based is more defined and prosecutable or defendable.
• There are also cost and time considerations for businesses to conform to this new proposed format with the potential for ambiguity leading to further confusion and misinterpretation.

Were a Principles Based system adopted then detailed guidance would be required to ensure we are meeting International standards that are Prescriptive Based.

It terms of weighing instruments, we prefer compliance-focused and/or rules-based. This will ensure we have a quality measurement system with no ambiguity which can lead to misinterpretation. The current compliance focused quality measurement system provides reliability and clarity to all parties.

Any device or process that underpins a financial transaction or would put the public at risk of death or serious injury through incorrect measurement, or in cases where measurement may form the basis of a legal case in the criminal or civil courts. The Scope should encompass areas discerning measurement in all facets, whether it uses trade approved or non-approved systems it still should be under the protection of Australia's Measurement Law to protect consumers, businesses, health and wellbeing of the Australian public.

The buyer and seller need confidence that they are protected against fraudulent declarations within a transaction. Where a transaction is based on a unit of measurement the Australian Measurement Laws should ensure that it is accurate within permissible tolerances. Australia’s measurement laws must provide for the confidence in suitability, accuracy and use of instruments.

We believe the Prescriptive based model clearly defines the requirements for quality and quantity measurement therefore should be applied. The vast majority of quality systems are based under Prescriptive models which govern Australian Industry. The combination of a Principles Base and Prescriptive Base system will create ambiguity in the market place.

In relation to Weighing Metrology, we believe there should be no exemptions when it comes to Trade and high risk Non-Trade applications where a legal case, injury or death may result through incorrect measurement. For example, Pharmaceutical, Transport, Maritime, Retail Trade, Work site Safety, Law Enforcement Health and Well being, Agriculture, negative Environmental impacts, etc.

The measurement framework needs to flexible to responsive to adapt to the changing technology in today's market place. A method for this is to allow provisions in a Pattern Approval to facilitate technological advancements without the need to rewrite the Regulation or Act.

Both. With the assistance the Weighing Industry we can facilitate compliance of Measuring instruments in the Australian Market through Pattern Approval and fixed Verification periods which will ensure correct measurement results.

Any instrument used in high risk Non Trade applications should be categorised and identified where a legal case, injury or death may result through incorrect measurement. Such as Transport, Maritime, Worksite Safety, Law Enforcement, Health and Wellbeing, Agriculture, negative Environmental impacts, etc. The approach for these high risk applications should be the same as Trade applications.

Any instrument used in high risk Non Trade applications where a legal case, injury or death may result through incorrect measurement. Such as Transport, Maritime, Worksite Safety, Law Enforcement, Health and Wellbeing, Agriculture, negative Environmental impacts, etc.
Additionally inline dynamic check weighers and other forms of automated weighing systems such as In-motion Axle Weighers may benefit from inclusion into the measurement system.

Yes we really need a national approach to Non-Trade measurements in areas where a legal case, injury or death may result through incorrect measurement. Such as Transport, Maritime, Worksite Safety, Law Enforcement, Health and Wellbeing, Agriculture, negative Environmental impacts, etc.