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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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
5.2.5 What is the appropriate form of ongoing monitoring and auditing of a UMV? - Open text field for response
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
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
Not Answered
7.2.4 What is an appropriate, effective and efficient way to monitor or audit the performance
of LMAs? - Open text field for response
Not Answered
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
Not Answered
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
Mostly, compliance arrangements for measurement in Australia appropriate, efficient and effective
How could it be improved:
1. Education : When Industry procure instruments with a Pattern approval, the NMI should work with the vendors to take the opportunity during the procurement transaction:
a. Determine if the instrument is going to be used for trade
b. If the instrument is used for trade, educate the users of the responsibility of maintaining the compliance of the instrument.
c. Provide details on relevant support of the instrument to maintain compliance
2. Systems/reporting:
a. Managing data – Improvement opportunity submitting forms:
i. Develop systems to allow servicing licensees to directly populate either manually or automatically forms on-line.
ii. Have systems to allow servicing licensees view submitted data, prepare reports or submit search enquiries.
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
Benefits: Developing a supportive frameworks between NMI and industry will provide role clarify and allow industry/users to set appropriate workable guidelines and enforcement rules.
Challenges: As new measurement technologies emerge to support existing measurements; the framework needs to be designed to facilitate rapid implementation.
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
If industry either identifies new measurement technology to improve existing instrumentation or a totally new technique to establish the value of products the frame work should allow an opportunity for industry to develop “Provisional approval” use of the technology. Such a “Provisional approval” would demonstrate:
1. Summary of measurements and usage
2. Establish the constraints of using the new technology.
3. Summary of tests conducted to determine the technology is fit for trade:
a. Reliability
b. Calibration techniques
c. Traceability of measurements
4. Industry communication and education
5. Dispute handling
Having such a framework would allow NMI to guide and support industry with the rapid and appropriate adaptation of new technology. With a Provisional approval type system, it would allow industry to establish an appropriate level of compliance to be established while protecting both sides of the transaction.
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
It is very important for that consumer protection legislation remains to strong so that it can be applied in cases of last resort, to resolve situations inaccurate measurement in a trade transaction
3.2.1 How should risk be applied to matters regulated by the measurement legislation? - Open text field for response
As measurement technologies development, industry might identify new approaches to demonstrate and monitor measurement performance. In principle, fully support accepting overseas approvals and arrangements for fast deployment of innovative technologies.
With this approach, it would support industry introduce efficiencies to the management and support of instrumentation or proactively monitor performance to identify potential issues.
Opportunity - Within the current NMI systems, there is a basic list of trade measurement requirements to determine that instruments are fit for trade. As a suggestion, if NMI had an application process available which would allow industry to demonstrate how it would address each of the major risks associated with trade measurements. For example:
1. Sealing of instruments
2. Verification performance
3. Verification instructions
4. Verification intervals
5. Application of suitable reference materials
6. Monitoring of instrument performance
3.2.2 In what ways could the measurement legislation deal with risk and how should this be
achieved? - Open text field for response
Fully supportive of a pragmatic approach to development of measurement legislation to facilitate effective trade between the producer and consumer on all levels. The key, is aligning the performance of measurements (reasonably achievable) with value of the transactions and intervals. To achieve this it requires open consultation with commodity traders and instrument suppliers, overseen by National Measurement Institute. This will ensure there is alignment of expatiations and trading standards.
When making changes, upmost care needs to be taken to avoid the unforeseen consequences.
3.2.3 Are there areas of measurement where a risk based approach is not appropriate? - Open text field for response
None identified at this stage.
4.2.1 What benefits and cost burdens does your business associate with compliance
monitoring inspections? - Open text field for response
Benefits
1. Provides a framework ensuring that all measurement instrumentation is fit for purpose and compliant.
2. Demonstrates to trading customers that the rigor of measurements is governed by NMI
3. Provides a consistent training standard.
Costs Burden
1. Within current environment, there is no flexibility or limited opportunity to introduce alternatives methods, while maintaining measurement rigor. The major cost burdens are:
a. Mobilisation of Servicing licensee – The verification periods of measurement instruments it drives the requirement to mobilise Servicing licensee to site. This requirement is regardless of condition/performance of instrumentation.
b. Training and competence of verifiers - It is very important to ensure that verifiers are competent. Having centralised systems in place to assess this are important. As a suggestion, adopting a complexity based training matrix would be advantageous. This could allow for in-house training and competency to be recognised for “non complex” measurement instrumentation.
4.2.2 Is the scope of compliance monitoring powers appropriate? - More Information
At this stage, level and experiences appropriate.
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
Removal of Verification intervals – Adopt an option that, if a servicing licensee can demonstrate to the NMI the on-going performance of measurement instruments within it’s control, the need for a verification interval be removed.
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
The escalating compliance approach is very pragmatic.
With the introduction of new technology and on-going updates to the compliance of measuring instruments, potential gaps could appear with owners’ obligations to the use of trade instruments. To help with education, establishing a central database of owners of trading instruments could be established. This could then be used to update owner:
1. Renewal of verifications
2. Updates to regulations
3. Training / equipment operation
Creating such a central database could be created as part of commissioning new trade approved instrumentation and re-verification process.
5.1.2 What has been your experience with NMI’s compliance options? How have you found them? - Open text field for response
Very positive. Having the opportunity and mechanisms to be able to proactively work together with the NMI to address areas within trade measurements is very important. This model very much outcomes focused.
5.3.1 What types of administrative options should be utilised as additional compliance
options? - Open text field for response
Agree
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