Adoption of OIML R 49
Response to Submissions
February 2015
1.
INTRODUCTION
In August 2014, the National Measurement Institute (NMI) released a consultation paper proposing
that the 2013 edition of OIML R 49 be adopted in Australia as the pattern approval standard for cold
potable water meters and hot water meters. If adopted, the pattern approval standard will be retitled
NMI R 49 Water Meters for Cold Potable Water and Hot Water.
The consultation paper and first draft of NMI R 49 are available on the NMI website.
The purpose of this document is to provide responses to the submissions that NMI received from
stakeholders regarding the consultation paper and first draft of NMI R 49.
The next steps regarding the publication of NMI R 49 will also be outlined.
2.
SUBMISSIONS
NMI received 12 unique submissions to the consultation paper from a range of stakeholders across
the water metering industry. In addition, NMI received numerous identical submissions responding to
specific questions concerning hot water meters and DN15 meters. Rather than addressing each
individual submission, this paper summarises the content of the submissions received and provides a
response to each of the issues in question.
3.
TECHNICAL REQUIREMENTS OF NMI R 49
3.1
General
The August 2014 consultation paper requested comments on the technical content of the first draft of
NMI R 49. Support for the proposed adoption of OIML R 49 was unanimous across all submissions.
NMI also received comments regarding the technical requirements of NMI R 49 in relation to ancillary
devices and water quality.
3.2
Ancillary Devices
NMI received a submission questioning the apparent mandatory application of clause 7.13 of
NMI R 49-2 to the Australian water metering industry. Clause 7.13 specifies the test procedures for
ancillary devices such as printing, memory and communications devices. The submission suggested
that clause 7.13 be made optional.
NMI recognises that numerous suppliers provide ancillary devices to the industry for use with
approved water meters. A similar clause exists in the current edition of NMI R 49. NMI interprets this
clause as allowing the voluntary inclusion of such ancillary devices with the scope of an approved
pattern of water meter. There appears to be little benefit in deviating from the current interpretation in
relation to ancillary devices.
3.3
Water Quality
NMI received a submission regarding specifications for the quality of water used for pattern approval
testing. Given that the most recent edition of Australian Standard AS 3565.1 Meters for cold and
heated drinking and non-drinking water supplies no longer specifies requirements for water quality, it
was suggested that such requirements be included in NMI R 49.
3.4
NMI proposals
NMI proposes that the adoption of OIML R 49 and publication of NMI R 49 continue based on
unanimous support from the submissions received and the benefits that will arise from aligning
Australian requirements with the latest international standard.
NMI proposes that the current interpretation regarding the testing and approval of ancillary devices
continue. In other words, clause 7.13 of NMI R 49-2 will be applied on a voluntary basis.
NMI proposes that water quality requirements, similar to those specified in previous editions of
AS 3565.1, be included in an informative appendix to NMI R 49. This will assist testing laboratories
and meter suppliers by providing guidance on minimum standards for water quality.
Appropriate amendments will be made to the next draft of NMI R 49, which will be released for
stakeholder comment in 2015.
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4.
PATTERN APPROVAL OF HOT WATER METERS
The August 2014 consultation paper requested stakeholder submissions regarding the current
restrictions on the pattern approval of hot water meters.
The vast majority of submissions received supported the removal of these restrictions, and the
introduction of voluntary pattern approval for hot water meters.
A number of questions and issues were raised in relation to hot water meters, specifically: the
appropriate use of hot water meters; the operation of a voluntary pattern approval scheme; and
technical and materials requirements, particularly for plastic components.
4.1
Use of Hot Water Meters
Some submissions argued that NMI should not pattern approve hot water meters as their use for trade
and billing purposes may be inappropriate. Furthermore, that hot water use should not be billed using
a hot water meter, but instead the energy used to heat the water should be billed using a gas or
electricity meter.
NMI does not specify when or where a utility meter should be used for trade or billing purposes, only
that if a utility meter is used, it should be accurate. Under current regulations, NMI cannot prohibit the
use of certain types of utility meters.
In addition, NMI does not specify requirements for the calculation of bills, utility unit prices or
conversion formulae. Such billing related requirements are mandated by the relevant State and
Territory regulators. NMI requires only that if the reading of a utility meter is used in the determination
of a bill, then the utility meter should be accurate.
The role of NMI is to ensure the accuracy of utility meters in use for trade via the mechanisms of
pattern approval and verification.
4.2
Voluntary Pattern Approval
As stated above, the proposal to remove the restrictions on the pattern approval of hot water meters
would establish a voluntary pattern approval scheme for these types of meters. Some submissions
indicated that this could introduce some confusion to the sector.
NMI has noted that potential confusion could arise due to the introduction of voluntary pattern approval
and will endeavour to provide guidance and explanation on the implementation of the scheme as
required. This may include the establishment of an industry committee to facilitate discussion on
technical matters relating to hot and cold water metering.
4.3
Technical and Materials Requirements
Some submissions indicated that consideration should be given to the specification of appropriate
materials and temperature ratings for cold and hot water meters.
NMI agrees that these issues are important. With respect to requirements for materials, these can be
found in AS 3565.1 and NMI does not intend to replicate these requirements with NMI R 49. These
requirements may be reviewed as part of future revisions of AS 3565.1.
With regards to temperature ratings, NMI R 49 specifies a range of temperature ratings (identical to
previous and current versions of OIML R 49) at which meters may be approved. NMI proposes to
retain these requirements.
4.4
NMI proposal
NMI proposes to remove the restriction on the pattern approval of hot water meters, thereby
establishing a voluntary pattern approval system for these meters. An amendment will be made to the
next draft of NMI R 49 to be released for stakeholder comment in 2015.
NMI will also endeavour to further engage with industry stakeholders regarding hot and cold water
meters. NMI would welcome input regarding the most effective means of engagement, such as further
consultation papers, fact sheets, industry committees or workshops.
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5.
FLOWRATE REQUIREMENTS FOR DN15 SIZED WATER METERS
The August 2014 consultation paper requested stakeholder submissions specifically regarding the
current Q3 and Q3/Q1 requirements for DN15 sized meters.
5.1
Submissions and Issues
Submissions regarding this matter were somewhat mixed, with the majority requesting that the
requirements be removed or amended to alternative Q3 and Q3/Q1 values. While other submissions
requested that the requirements be retained.
NMI acknowledges that there are risks and benefits associated with each option. Amending or
removing the requirements may allow for greater availability of smaller meter types within the
Australian market whilst also reducing the potentially significant costs of re-designing meters in order
to comply with these requirements.
On the other hand, removing the requirements may decrease consumer protection by reducing the
flowrate range over which the meter is required to operate accurately. However, NMI considers that
these risks can be managed appropriately by continuing to ensure that all pattern approved meters are
properly marked with the approved flowrate information, allowing water service providers to make
informed decisions regarding the use of appropriately sized meters.
5.2
NMI proposal
NMI proposes to remove the current Australian Q3 and Q3/Q1 requirements for DN15 sized meters and
align fully with OIML R 49 requirements. An amendment will be made to the next draft of NMI R 49,
which will be released for stakeholder comment in 2015.
Meter marking/inscription requirements in relation to Q3 and Q3/Q1 will remain consistent with OIML
requirements for all meter sizes, including DN15.
This proposal will reduce costs to meter suppliers and closely align Australian requirements with our
international trading partners, thereby increasing market access and decreasing costs, while also
continuing to provide appropriate information to water service providers and consumers.
6.
NEXT STEPS
1. NMI will incorporate the proposed amendments outlined above into a second draft of NMI R 49.
2. The second draft of NMI R 49 will be released for public comment on the NMI website in 2015.
3. Comments received will be considered as part of the development of a final draft. Further
consultation will be undertaken as appropriate before publication of NMI R 49.
4. NMI will consider additional stakeholder engagement opportunities in order to increase
awareness and understanding of the application of NMI R 49 in relation to cold and hot water
meters as well as resolving technical matters as they arise.
7.
CONTACTING NMI
If you have questions regarding the content of this document, or the adoption and publication of
NMI R 49, please contact NMI either by:

emailing [email protected] with the subject heading
“NMI R 49” and your company or individual name.

mailing your submission with the subject heading
“NMI R 49” and your company or individual name to:
Legal Metrology Policy (Attention: NMI R 49)
National Measurement Institute
PO Box 264
Lindfield NSW 2070
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