CCURG Government Agencies
Productivity Commission:  Standards & Accreditation Submission
Supplementary Comment No. 2

Background:  The following observations are forwarded to applify comments made in CCURG Submissions No. 115 and 144, the latter being in part, a response to Standards Australia (SA) Submission No. 122.  The observations arise from drilling down to a lower level of detail to allow comparison of Aust Stds with ISO, British and other standards.

ISO Practice:  "ISO/IEC Guide 59:1994, Code of good practice for standardization" as previously noted, has been acknowledged by Aust Stds in Standardization Guide SG-007, Clause 2, "as a useful reference document" and the following observations are made to it:
•	"Clause 5.7  Administrative requirements relating to conformity assessment and marks of conformity or other, non-technical issues should be presented separately from technical and/or performance requirements."  It is understood that SA policy has recently been determined from this clause (also note BSI Practice below).
•	General:  Guide 59 was reviewed for advice on conformity and just two references were found.  The first was Clause 5.7 which assumes conformity assessment is a fundamental inclusion and the second was Annex A.
•	"Annex A  Terms and definitions in relation to GATT Agreement on Technical Barriers to Trade", although informative, "Clause 3  Conformity-assessment procedures" again suggests conformity is a fundamental inclusion.
•	Conformity standards:  ISO 3269:2000 and ISO 16426:2002 for fasteners, have previously been cited as examples.

BSI Practice:  British Standards (BSI) have an equivalent document to SA’s HB 162-2002, namely:
                            BS 0:2005  A standard for standards,  Part 1:  Development of standards – Specification      &
                                                                                         Part 2:  Structure and drafting – Requirements and guidance.
“Part 2, Clause 4.4  Conformity, compliance and verification”, references “Part 1, Clause 5.8  Conformity attestation”, and some observations from this clause are:
•	Paragraph 5.8.1:  “BSI shall ensure that...conformity to a standard can be declared without recourse to third party attestation”.  This aligns with ISO/IEC Guide 59, "Clause 5  Advancement of international trade, Paragraph 5.7".  
•	Paragraph 5.8.2:  “A product….specification shall contain clear statements of how conformity to all it’s requirements can be verified (eg. by specifying methods of test or of measurement)”.

Over the last twenty years, British standards have had to face considerable change, however BSI’s  "A standard for standards" confirms that conformity has always been rigorously addressed as a normative requirement.  Aust Stds with both, the existing HB 162-2002 requirements, and in the recent proposal to have conformity and attestation (ie: formal confirmation) included in a new Part 2 of Aust Stds, are non-aligned with BSI requirements.  Also as the latter needs to align with EN, it follows that Aust Stds are therefore non-alignment with all member states of the European Union.

EN Practice:  In Submission 122, SA claimed that “Euronorms are drafted in quite a different way to national standards outside Europe because they form part of the European regulatory system.  Within the European Union, each member state is required to introduce uniform legislation requiring mandatory certification of products offered for sale against Euronorms wherever this is specified in the relevant EU directive.”
•	The UK Office of the Deputy Prime Minister has confirmed that “the UK did not make CE marking mandatory”.  Hence presumably all other member states would equally also have this opportunity.  
•	The SA statement also flies in the face of recent Stds Aust initiatives to clone selective EN standards.

CSA Practice:  Time prohibits a similar review of Canadian standards to that of British standards, however all CSA standards used in the recent preparation of CCURG cement specs, have included normative conformity.

Summary:  It would appear that SA, in choosing to reject conformity as a fundamental inclusion, has not met the expectations of ISO and has made Aust Stds non-aligned with the standards practices of Britain, Europe and Canada.

Jeff Gleeson
CCURG Chairman
10 October 2006

On behalf of CCURG Participating Government Agencies

Copy:  ABCB