Organisation Internationale de Mtrologie Lgale International Organization of

Organisation Internationale de Métrologie Légale International Organization of Legal Metrology The work and structure of the OIML Bogotá, Colombia 29 -30 May 2019 Ian Dunmill Assistant Director Bureau International de Métrologie Légale (BIML)

What will I cover? • What is legal metrology? • What is the OIML? • What does the OIML do? • The structure of the OIML • The OIML’s technical work • Cooperation with other international organisations • The International Convention for the Safety of Life at Sea (SOLAS)

Definition of legal metrology “Legal metrology is the practice and the process of applying regulatory structure and enforcement to metrology. It comprises all activities for which legal requirements are prescribed on measurement, units of measurement, measuring instruments and methods of measurement, these activities being performed by or on behalf of governmental authorities, in order to ensure an appropriate level of credibility of measurement results in the national regulatory environment…. ” (OIML D 1: 2012 “Considerations for a law on metrology”) 3

Definition of legal metrology “Legal metrology is the practice and the process of applying regulatory structure and enforcement to metrology. It comprises all activities for which legal requirements are prescribed on measurement, units of measurement, measuring instruments and methods of measurement, these activities being performed by or on behalf of governmental authorities, in order to ensure an appropriate level of credibility of measurement results in the national regulatory environment…. ” (OIML D 1: 2012 “Considerations for a law on metrology”) 4

What does legal metrology cover? 5

What does legal metrology cover? 6

What does legal metrology cover? 7

What does legal metrology cover? 8

What does legal metrology cover? 9

When does legal metrology affect you? • • Every time you buy fruits, vegetables, meat, fish … Every time you buy products in a box, a can, a jar. . . When you use utilities at home – electricity, gas, water. . . When you fill your car with fuel. . . When you drive – speed, alcohol, emission controls. . . When you visit the doctor or hospital. . . When you go to work – levels of light and noise. . . Do you think about these things. . . or does “somebody look after them” for you? 10

Legal metrology affects the whole economy • Consumer level – shops / markets / filling stations / utilities Affects everyone’s daily life • Industrial level – processed / packaged products – trade in measuring instruments Affects a large number of companies in a given country • National level – international trade in raw materials / fuels Affects national economies 11

Who looks after metrology at the international level? Scientific/industrial metrology • Bureau International de Poids et Mesures • Established in 1875 • Sèvres, France Legal metrology § Organisation Internationale de Métrologie Légale § Established in 1955 § Paris, France 12

OIML Membership 13

OIML Member States • Have acceded to the OIML Convention • Pay subscription based on four population classes: <10 million 10 40 million 40 100 million >100 million • • Possibility of reduction of class based on GNI/capita Can participate in all meetings and technical work Full voting rights at all levels Represented by Member of the International Committee of Legal Metrology (CIML Member) 14

OIML Corresponding Members • Have not acceded to the OIML Convention • Currently pay fixed subscription of 1/10 minimum Member State contribution • Can participate in meetings and technical work as observers • No voting rights at any level 15

OIML structure International Conference of Legal Metrology (government delegations) International Bureau of Legal Metrology (BIML) International Committee of Legal Metrology (CIML) President (government appointed members) Presidential Council Technical work structures

OIML publications (1 of 3) • International Recommendations (R) Intended as harmonized model technical regulations which Member States have a moral obligation to consider, and follow as far as possible, when setting up national or regional legal metrology regulations • International Documents (D) Informative technical publications which are intended to facilitate the implementation or development of Recommendations. They may include technical guidance (e. g. D 11 General requirements for measuring instruments Environmental conditions) • Vocabularies (V) Harmonized vocabularies which should be used as far as possible in all other OIML publications

OIML publications (2 of 3) • Guides (G) Informative publications giving advice on “best practice” • Expert reports Publications intended to provide information and advice to metrological authorities. Expert Reports are commissioned by the CIML President or by the BIML Director, or proposed by authors. They are written solely from the viewpoint of their author, without the involvement of a Technical Committee or Subcommittee, nor that of the CIML. Thus they do not necessarily represent the views of the OIML *

OIML publications (3 of 3) • Seminar reports Contain seminar proceedings and presentations, organized under the auspices of the OIML • Basic publications (B) Set out the general operating rules of the Organization. Basic publications are not regarded as representing technical work • OIML Bulletin Quarterly journal of news and developments in legal metrology

Technical work structure Technical Committees and Subcommittees TC 1 SC 1 TC 2 SC 2 TC 3 SC 4 TC 4 SC 5 . . TC 5 SC 1 SC 2

Technical work structure Responsibility for publications TC 1 TC 2 V 1 G 18 D 2 SC 1 SC 2 D 13 D 19 D 20 D 27 D 9 D 12 D 16 SC 3 D 18 TC 3 TC 4 R 34 R 42 D 1 D 3 G 1 D 5 D 8 D 10 D 23 SC 4 SC 5 D 29 D 30 B 3 B 10 TC 5 SC 6 . . SC 1 SC 2 D 11 D 31

Technical work structure TC 1 TC 2 TC 3 TC 4 V 1 G 18 D 2 R 34, R 42, D 1, D 3, G 1 D 5, D 8, D 10, D 23 TC 5 p 6 – D 23 p 2–D 5 p 8–D 8 p 9 – D 10 . . p 3 – G 18 SC 1 SC 2 SC 3 D 13, D 19 D 20, D 27 D 9, D 12 D 16 D 18 SC 4 SC 5 SC 6 D 29, D 30 B 3, B 10 p 2 – new Publication p 1 – new Publication p 7 – new Publication p 1 – new Publication p 5 – new Publication p 12 – D 30 p 1 – new Publication SC 1 SC 2 D 11 D 31 p 2 – new Publication p 3 – D 31

OIML Website Accessing public information on technical work

OIML Website Accessing public information on technical work

OIML Website Accessing public information on technical work

OIML Website Accessing public information on technical work

OIML Website Accessing public information on technical work

Composition of groups in technical work • Participating members (P-members) • At least six P members from at least two different regions • P Members are obliged to participate in the work of the TC/SC and to vote on all proposals • Only OIML Member States can be P members • The secretariat of a TC/SC or convenership of a PG is allocated to one of its P members

Composition of groups in technical work • Observing members (O-members ) May participate fully in the work of the TC/SC/PG, but do not have the right to vote. O members may be Member States or Corresponding Members • Liaisons Organizations which are neither Member States nor Corresponding Members. They may participate fully in the work of the TC/SC/PG, but do not have the right to vote • A BIML contact person

The work of Project Groups Project Group Convener: Country F P-members: A, B, C, D, E, F, G, H O-members: I, J, K, L Develops one publication Part 1 Metrological and technical requirements WD Part 2 Test procedures Part 3 Test report format WD WD (for type approval, verification and inspection) 1 CD 2 CD

The work of Project Groups CD approved by Project Group CIML preliminary ballot CIML approval Publication Conference sanction Five yearly review

The International Convention for the Safety of Life at Sea (SOLAS)

The International Convention for the Safety of Life at Sea (SOLAS) • Original Convention passed in 1914 following Titanic disaster • Rewritten in 1974 – came into force in 1980 • 2015 amendment to add Container Weight Verification Regulation VI/2

Why was container weighing needed? • Shippers previously declared container weight but there was no obligation to measure it! • Inaccurate declarations – deliberate or accidental • Accurate weights needed to plan safe loading of ships • Over declared weights are as dangerous as under declared weights!

Why was container weighing needed?

Why was container weighing needed?

Why was container weighing needed?

Container Weight Verification Regulation VI/2 • Verified gross mass of containers must be obtained before container is loaded onto ship • New Electronic Data Interchange communication protocol VGM (Verified Gross Mass) or VERMAS (Verification of Mass) • Shippers are responsible for obtaining and sending verified gross mass • Came into force 1 July 2016 • Implementation phase until 1 October 2016

Two methods of obtaining weight • Method 1 • Weigh the packed and sealed container • Method 2 • Weigh all the cargo • Weigh the packing and securing materials • Take tare weigh marked on container • Add all these values

Some metrological and legal problems to consider

Common standards? • Weighing instruments “must meet the applicable accuracy standards and requirements of the State in which the equipment is being used” IMO Guidelines, paragraph 7. 1 • Requirements could vary across the world unless a common “accuracy standard” is used

Scope of legislation • Are there any requirements at all in some countries? • Does legislation cover this application? – Legal metrology legislation may cover trade use only • In Europe it does according to – Non automatic weighing instrument directive – Measuring instrument directive

NAWI directive scope 2009/23/EC Article 1 2. For the purposes of this Directive, the following categories of use of non automatic weighing instruments shall be distin guished: (a) (i) determination of mass for commercial transactions; … (a) (iii) determination of mass for the application of laws or regulations or for an expert opinion given in court proceedings; . . .

NAWI directive scope 2009/23/EC Article 1 2. For the purposes of this Directive, the following categories of use of non automatic weighing instruments shall be distin guished: (a) (i) determination of mass for commercial transactions; … (a) (iii) determination of mass for the application of laws or regulations or for an expert opinion given in court proceedings; . . .

MID scope 2004/22/EC Article 2 1. Member States may prescribe the use of measuring instruments mentioned in Article 1 for measuring tasks for reasons of public interest, public health, public safety, public order, protection of the environment, protection of consumers, levying of taxes and duties and fair trading, where they consider it justified.

MID scope 2004/22/EC Article 2 1. Member States may prescribe the use of measuring instruments mentioned in Article 1 for measuring tasks for reasons of public interest, public health, public safety, public order, protection of the environment, protection of consumers, levying of taxes and duties and fair trading, where they consider it justified.

Specific exemption concern • “Individual, original sealed packages that have the accurate mass of the packages … clearly and permanently marked on their surfaces do not need to be weighed again when they are packed into the container” IMO Guidelines, paragraph 5. 1. 2. 1 • Requirement for verification of this value appears to be missing

Consistency of weight values • “Weights obtained … by Method 1 or by … Method 2 are to be as accurate as the scales or weighing devices used …” • Need to ensure that same overall accuracy requirements apply whichever instrument capacity and technology is used

Units of measurement • “The verified weight should be expressed in kilograms or pounds, depending on which measure is used in that jurisdiction” • Only kilograms are used in the International System of units (SI) • Use of kilogram ensures traceability of measurement • Use of the word “should”?

How can the OIML help with SOLAS? • Reliability of VGM system depends on sound basis for measurements taken • OIML Recommendations are widely used worldwide in legislation • Legal metrology systems are already established worldwide for: • type approval • verification • inspection

Use OIML Recommendations • R 76 Non-automatic weighing instruments

Use OIML Recommendations • R 51 Automatic catchweighing instruments

Use OIML Recommendations • R 51 Automatic catchweighing instruments

Use OIML Recommendations • R 60 Load cells

Use OIML Recommendations • R 106 Automatic rail-weighbridges

Use OIML Recommendations • R 134 Automatic instruments for weighing road vehicles in motion and measuring axle loads

Where to weigh containers? • Before arrival at the port – only way if Method 2 is used • On arrival at the port – slows down vehicle/container processing • During port handling – disruption of process? • During ship loading – too late for stowage plan!

Risks with Method 2? • Adding weights of container contents means adding errors/uncertainties • Can only be done immediately before sealing – ensures all dunnage is included – ensures nothing added • Addition of items at different places allowed? • Cannot be used at a port facility?

Practical problems One container … … or more?

Practical problems Single stack … … or double?

Does it go far enough? No requirements for eccentric loading of containers which have to travel by road or rail to the ports!

Experience since 2016 • Bottlenecks which were expected have mainly not arisen • Some manufacturers initially had problems with type approval / verification of equipment • Many shippers suspected to have done nothing except change their declarations to electronic form and wait for audits to happen • Many countries not yet auditing declarations • Some don’t intend to start!

Experience since 2016 • Significant variations in accuracy requirements • Significant differences in penalties imposed for non compliance – some severe – some worthless or non existent • No current plans for WMO to amend system

Thank you ian. dunmill@oiml. org www. oiml. org