Measurement Assurance

What is your name? - Name

What is your organisation? - Organisation

Comments - respondent submission

2.4.1 Are there other functions within the measurement system which could be
implemented via third party arrangements? If so, which areas? - Open text field for response

2.4.2 Do the current third party arrangements add value to the metrological system?
Do they impose unnecessary regulatory burden? - Open text field for response

2.4.3 Are there functions within the measurement system currently implemented by third
party arrangements which should be implemented by the Australian Government instead?
If so, which areas and why? - Open text field for response

4.1.1 Should we continue to have a servicing licensee system? Why or why not? What is the
value to businesses and to the community? - Open text field for response

4.1.2 Should the current arrangements for granting a servicing license continue? How can
the process of licensing be streamlined or improved? How appropriate and efficient are the
current licensing requirements? - Open text field for response

4.1.3 How can ongoing competency of verifiers be ensured and facilitated? Is the required
level of competency appropriate? What alternatives might be considered to an RTO‑issued
statement of attainment? - Open text field for response

4.1.4 How important is the servicing licence to your business? What percentage of your
business activity involves carrying out verifications under the licence? - Open text field for response

4.1.5 How appropriate and efficient are the current reporting requirements? What is the
appropriate level of ongoing monitoring and auditing of verifiers and licensees? Are the
current compliance and enforcement options effective? - Open text field for response

5.2.1 Should the current system for UMVs be maintained and why? What is the value UMVs
provide to businesses and to the community? - Open text field for response

5.2.2 How different is a UMV to a verifier of a trade measuring instrument under a Servicing
Licence? Do utility meters need to be verified by a separate category of third party? If so,
why? - Open text field for response

5.2.3 How can the process of appointment for UMVs be improved? How appropriate,
effective and efficient are the current requirements and conditions for appointment as a
UMV? - Open text field for response

5.2.4 What is the appropriate level of competency that should be required for a UMV? Is the
current accreditation requirement appropriate, effective and efficient? - Open text field for response

5.2.5 What is the appropriate form of ongoing monitoring and auditing of a UMV? - Open text field for response

6.2.1 Has the need for public weighings changed? Should public weighbridges continue to
be licensed? Is there a need to treat ‘public weighbridges’ differently to other weighbridges?
Does this differing treatment create a disincentive for operators to provide access to a
weighbridge as a public service? - Open text field for response

6.2.2 Should public weighbridges have a reverification period? If so, how often should they
be reverified, noting the current requirement is every 12 months? Should a more flexible
approach be taken? - Open text field for response

6.2.3 How can the licensing and reporting requirements of licensees be streamlined and
improved? - Open text field for response

6.2.4 Which requirements are the most important for licensees and operators?
Which requirements are burdensome, can be made less prescriptive or do not contribute to
accuracy of the weighbridge? Which requirements could be removed, reduced or changed? - Open text field for response

6.2.5 How can ongoing competency of weighbridge operators be ensured and facilitated?
Is the currently required level of competency appropriate? What alternatives might be
considered to an RTO-issued statement of attainment? - Open text field for response

7.2.1 Should the Chief Metrologist continue to appoint LMAs? What value does appointment
of LMAs provide to businesses and the community? - Open text field for response

7.2.2 How appropriate are the current appointment and competency requirements for LMAs?
Should certifying authorities for reference materials be required to hold accreditation to ISO
17034 as well as or instead of ISO 17025? - Open text field for response

7.2.3 If there was a general condition to report to NMI on the performance of activities
undertaken under the appointment, what are the main barriers for LMAs and how could these
barriers be overcome? - Open text field for response

7.2.4 What is an appropriate, effective and efficient way to monitor or audit the performance
of LMAs? - Open text field for response

7.2.5 How important is the appointment as an LMA to your business? What percentage of
your business involves carrying out LMA functions? - Open text field for response

7.2.5 How important is the appointment as an LMA to your business? What percentage of
your business involves carrying out LMA functions? - Continue or submit

2.3.1 Is the focus of the compliance arrangements for measurement in Australia appropriate,
efficient and effective? How could it be improved? - Open text box for response

2.3.2 What are some of the benefits or challenges of a more modern approach to compliance
arrangements for Australia’s measurement framework? - Open text field for response

2.3.3 How could compliance arrangements for Australia’s measurement framework be made
more flexible while remaining sufficiently robust? - Open text field for response

2.3.4 To what extent should legislation outside the measurement framework—for example,
consumer protection legislation—be relied upon to provide remedies and compliance options
where there has been inaccurate measurement in a trade transaction? - Open text field for response

3.2.1 How should risk be applied to matters regulated by the measurement legislation? - Open text field for response

3.2.2 In what ways could the measurement legislation deal with risk and how should this be
achieved? - Open text field for response

3.2.3 Are there areas of measurement where a risk based approach is not appropriate? - Open text field for response

4.2.1 What benefits and cost burdens does your business associate with compliance
monitoring inspections? - Open text field for response

4.2.2 Is the scope of compliance monitoring powers appropriate? - More Information

4.2.3 What alternatives are there to the current compliance monitoring framework? How else
can compliance be monitored/incentivised? - Open text field for response

4.2.4 How can the compliance arrangements be established to be transparent but also able
to flexibly adapt to changes in the economy? - Open text field for response

5.1.1 Are the current compliance options available sufficient/appropriate? Where are there gaps? - Open text field for response

5.1.2 What has been your experience with NMI’s compliance options? How have you found them? - Open text field for response

5.3.1 What types of administrative options should be utilised as additional compliance
options? - Open text field for response

5.4.1 Is the current infringement notice amount of 5 penalty units ($1,050) appropriate for
all offences? - Open text field for response

5.4.2 Should greater flexibility apply to the amount to be paid under an infringement notice?
If so, how? - Open text field for response

5.6.1 What might be the benefits/disadvantages of moving to a primarily civil penalty
regime? - Open text field for response

5.6.2 Are there additional powers that should be given to courts to enable more flexible
outcomes? - Open text field for response

5.7.1 Should the legislation include both civil and criminal penalties? - Open text field for response

5.7.2 Which of the current offence provisions in the measurement legislation warrant civil
penalties only, and which would warrant both civil and criminal penalties being available? - Open text field for response

5.8.1 How could statutory defences and/or exemptions play a role in improving compliance? - Open text field for response

5.8.2 Should the Minister be given the power to exempt certain instruments or classes of
instruments from the operation of parts of the measurement framework? If so, what
restrictions should be imposed on this power? - Open text field for response

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