CECIP Meetings

I have recently attended the General Assembly for CECIP in Dresden on the 3rd and 4th May. This was preceded by a meeting of both the LMG (Legal Metrology Group) and the BTG (The Business and Trade Group).

LMG Meeting
This was useful meeting and a lot of important matters were discussed.

Review of the groups’ organisation
There was an important review of the way we had dealt with the matter of 10v/m so far and whether this could have been improved. This was useful and open discussion. The conclusion was that the structures of the LMG and CECIP are satisfactory, but it is very important for all members of the group to participate fully. There is often a lot of useful information and it is often difficult to find the time to read and make sensible decisions on this, however, there was no real alternative. It was incumbent on all national associations to ensure there members are informed.

Presentation on the New Legislative Framework (The NLF)
A presentation was made, outlining some of the important changes which the new NAWI and MI Directive may bring. This raised many of the points that had been raised at the UKWF Regional Meeting. I would advise that you read this presentation (below) and let me have any comments.

CECIP Presentation on NLF

10v/m
A long discussion on this took place. It was recognized that we are now back at the beginning of the process and it was decided that it was most important that we have a common CECIP position statement for future negotiations. This was a productive discussion and the conclusion was:

1. That there must be at least a one year transition period from the date that the new standard is published.
2. That all existing type approval documents must be allowed to expire.

It was felt that this reflected an acceptable position for future developments. There was some concern as to the method by which it could be allowed that exiting type approvals continue.

Manufacturer
There was an important discussion on the WELMEC position relating to the definition of manufacturer. It was agreed that the WELMEC view would have a detrimental effect on SME’s and this position must be challenged at all opportunities.

Guests to the meeting
The meeting had the pleasure of Anneke Van Spronssen, the chairperson of WELMEC and Roman Schwarz from the PTB. This was an excellent opportunity to discuss these matters with both people and to clarify the position of CECIP especially in relation to the issue of manufacturer where it appears that there was some confusion on the part of WELMEC.

Roman Schwarz outlined the definition of the KG in terms of a physical constant. It was outlined to Roman Schwarz that there was some concern that the practical implications of the definition had not yet been properly thought through. It was important that the general public must understand the source of the units if they are to have credibility.

BTG Meeting
The BTG meeting spent much of the time discussing the position relating to 10v/m. There was some concern raised as to the position of the PTB and how they unilaterally decide to test at 10/v. After considerable debate on the position that CECIP should take on this matter, it reflected that considered at the LMG meeting.

The General Assembly Meeting
This was an important meeting, with a wide range of interesting and useful speakers:

1. Mr. Vicente Leoz Arguelles: Latest EU Policy Developments. A sectoral perspective:

This was an interesting presentation on the development of the NLF and the commissions view on the implications of this on businesses. There was general agreement that this would largely make explicit the obligations that businesses should be operating to already. There was some concern raised from the audience on the potential impact on micro-businesses, if sufficient clarification of the directives was not given.

It is felt that Mr. Arguelles listened to the concerns of the industry and is happy to take our comments seriously.

2. Anneke van Spronnsen: WELMEC: The next challenges of WELMEC and the role of industry

This was a positive presentation that outlined many of the present debates that we are involved in, from the point of view of WELMEC. It was good to see that Anneke was keen to hear our views and happy to consider them, although clarified that any final decisions would be made by the WELMEC committee. It was positive to see that both WELMEC and CECIP are happy to move forward from the market surveillance project and to ensure positive co-operation in the future.

3. Rita L’Abbatte: A roadmap to improve market surveillance in the EU

This was a difficult presentation, looking at the road map to market surveillance. This is a document outlining the Commissions policies on this subject. If you would like a copy of the roadmap please get back to me. It was noted that from the point of view of the weighing sector, the policy focused too closely on consumer safety and did not outline the importance of market surveillance for the purposes of market regulation.

4. Other presentations

The remainder of the meeting consisted of reports from the LMG and the BTG and the reports from the member associations. If you would like copies of these reports please let me know.

The next CECIP General Assembly next year is the 1st to the 4th of May in the Netherlands. As soon as I have more details, I will let you know.

Ian Turner
UKWF Technical Officer

NoBoMet Meeting (18th May 2012)

I have attended the meeting of the Notified Body Metrology (NoBoMet) Meeting at the PTB in Germany. This is a European grouping of notified bodies that undertake work on the whole range of weights and measures equipment. The grouping is at an early stage and we will need to see how it develops.

There was some discussion on the administrative nature of the group and it was good to see that it was planned that it should be an open group with all stakeholders being involved. There was a lengthy discussion on the matter of 10v immunity and how the different notified bodies are treating this matter. It was interesting to note the PTB would only test instruments to 10v. Other notified bodies would offer both and some would test only to 3v.

CECIP commented that this lack of consistency was unhelpful. Although many of the larger manufacturers would understand the important issues, many of the smaller ones would not. These companies look to the notified body for help and assistance and it is important that consistent advice is given in all member states

It was a useful opportunity for CECIP to clarify their view on the 10v issue. It was noted that CECIP are concerned that after the new standard is published, an appropriate transition period for the new standard is crucial. It was also noted that we find it unacceptable if existing type approval certificates are not allowed to expire at the end of their life. These comments were noted by the group and there was a general sense of agreement to the position.

There was a long discussion on the potential time schedules for the production of the new standard and the possible implications of this. The rest of the meeting was spent discussing technical issues in relation to other measuring instruments.

It would be my view that the meeting was worth attending to ensure that we take every opportunity to engage with all stakeholders to ensure our views are heard. The value of the group will become apparent over the next few meetings. I feel it would be too early at this stage to make a judgement. If you would like any more information on this please let me know.

The group has a website which can be found at https://sites.google.com/site/portalnobomet/home.

It is a useful vehicle for us to make our views known, so if you have any issues that you would like me to bring up with regard to notified bodies please let me know.

There is likely to be another meeting in October 2012 which I plan to attend.

Parallel type approvals

We are, at present, involved in an important discussions with both WELMEC and the EU Commission relating to the definition of “manufacturer” as used in the Non-Automatic Weighing Instruments (NAWI) and the Measuring Instruments Directive (MID)Directive.

There is an argument that only the manufacturer who owns the type approval can undertake self-verification (Module D) or verification by a third party (Module F).

The view of the UKWF and CECIP is that the person that can undertake verifications is the person who is prepared to sign the Declaration of Conformity and put the instrument on the market. This means that they do not have to be owner of the Type Approval. This is the system that we presently operate in the UK.

This is an important matter that could result in many manufacturers needing to obtain parallel type approval documents to continue operating their business. This is a type approval that will be the same as the original, with different names and addresses on.

If this could have an effect on your business, I urge you to contact your local MEP to encourage them to pursue the matter for you

I attach a link for a draft letter that you could use to send to your MEP

 

Parallel Type Approvals