Archived — Forestry Trade Sector Review — Recommendations for Establishing Measurement Canada’s Level of Intervention in the Forestry Trade Sector Review - Final Report

Archived Information

Archived information is provided for reference, research or recordkeeping purposes. It is not subject to the Government of Canada Web Standards and has not been altered or updated since it was archived. Please contact us to request a format other than those available.

Table of Contents

1.0 Introduction
1.1 Purpose of the Report
1.2 Background
1.3 Clarification of Scope
1.4 Reference Material
1.5 Decision Making Criteria
1.6 Methodology of Consultation
1.7 Decision Criteria
1.8 Impact on Other Trade Sector Reviews
1.9 Stakeholder Reach
1.10 Acknowledgements

2.0 Acronyms

3.0 Forestry Sector Recommendations (Summary)
3.1 Forest Sub-Sector
3.2 Retail Firewood Sub-Sector

4.0 Forestry Recommendations (Detailed)
4.1 Approvals
4.2 Initial Inspections
4.3 Periodic Inspections
4.4 Legislation
4.5 Physical Standards
4.6 Complaints
4.7 Marketplace Monitoring

5.0 Retail Firewood Sub-Sector Recommendations (Detailed)

Appendix 1 - List of Registered Stakeholders

Appendix 2 - Results from the Forestry Trade Sector Review Questionnaire

1.0 Introduction

1.1 Purpose of the Report

The purpose of this report is to provide Measurement Canada’s senior management with recommendations for establishing an appropriate level of metrological intervention in the Canadian forestry trade sector.

1.2 Background

The forestry trade sector review team, consisting of six individuals from across Canada, has performed extensive Canada-wide consultations with various forestry sector stakeholders. Stakeholders have included aboriginal and non-aboriginal Canadians, large and small forestry companies, provincial and territorial governments, logging truck operators, forest workers, and manufacturers of wood products and services.

Input from initial consultations and from stakeholder questionnaire feedback was used in the development of draft recommendations contained in a discussion paper, issued September 2006. The discussion paper also contained research information on what other developed countries are doing in regards to legal metrology in the forestry sector. Following the issue of the discussion paper, five cross Canada stakeholder consultation meetings were held between October 2006 and January 2007. Input from these meetings has also been used in preparing the final recommendations contained in this report.

This report summarizes forestry sector stakeholder’s thoughts and concerns on an array of trade measurement issues and provides Measurement Canada senior management with the supporting rationale and considerations behind each recommendation.

Although input during the review indicated the vast majority of stakeholders want Measurement Canada to continue to perform device inspections in this sector, once given Measurement Canada’s need to move to alternative service delivery for this work, stakeholders provided input as to the best direction to proceed.

1.3 Clarification of Scope

The scope of this review includes measurement devices used in the trade of forest products in Canada. The review also includes devices Measurement Canada has not traditionally been involved with, such as devices used to measure (cruise) standing trees and linear measures used to scale fallen logs. The scope of the review also includes the buying and selling of firewood.

Devices used to weigh recycled paper, in its unfinished form, wood alcohol and resins are not included in the scope of this review. These forest products will be included in the reviews of the Canadian waste and re-cycling trade sector review and in the Canadian chemical industry trade sector review, respectively. These reviews are scheduled to be completed at a later date.

1.4 Structure of the Report

The report has been structured to:

  • provide an understanding of the consultation process used for this project.
  • identify the stakeholder groups who participated in the Forestry Trade Sector Review (FTSR) initiative.
  • identify the different measurement applications within the sector.
  • identify the current services and programs provided by Measurement Canada and those recommended by the stakeholders.
  • identify the key considerations for the recommended programs.
  • identify major stakeholder concerns and comments about matters pertaining to the FTSR.

The report recommendations have been divided into two parts. The first part pertains to forestry trade excluding the retail firewood sub-sector. The second part pertains to the retail firewood sub-sector only.

1.5 Reference Material

The FTSR report entitled, a Discussion Paper on Establishing an Appropriate Level of Intervention in the Forestry Trade Sector, was published in September 2006. The FTSR team distributed this paper to all parties who had previously shown interest in the initiative. The paper was also posted on the Measurement Canada's website. Meeting minutes were prepared and distributed to those stakeholders who attended one or more of the five consultation meetings held during the fall of 2006 and winter 2007.

Other reference material includes the Canadian Standards Association CSA 0302.1-00/0302.2-00 Scaling Roundwood/Measurement of Woodchips, Tree Residues and Byproducts and The National Institute of Standards and Technology (NIST) Handbook 44 and Handbook 103.

1.6 Methodology of Consultation

Since September 2005, the FTSR team has contacted, met and solicited input from more than 500 stakeholders from various areas of the forest industry. A list of registered stakeholder organizations is included in appendix 1 of this report.

The methods used to solicit input included:

  • stakeholder information sessions;one-on-one meetings;
  • presentations at industry conferences and policy forums;
  • telephone calls;
  • Measurement Canada Sector Review - Forestry;
  • email;
  • direct mail-outs;
  • stakeholder questionnaires.

Stakeholders were contacted in the initial phase of this initiative to update them with Measurement Canada's programs and the Trade Sector Review process. During this phase the FTSR team investigated current trade measurement practices employed in this trade sector as well as solicited the views of stakeholders regarding what future measurement programs they would like to see in the industry and how these programs could be best provided. The information obtained from these meetings and other research was used in the development of the FTSR discussion paper.

The FTSR team also developed and distributed a questionnaire to forestry stakeholders they met with during the initial consultation phase of the review. A surprising 262 completed questionnaires were returned. Responses came from a variety of stakeholders; individual forest workers, log haulers, provincial ministries of forest, device service companies, large and small forestry saw mills, pulp and paper companies and wood products processors. This input was also used in the preparation of the draft recommendations contained in the FTSR discussion paper. A summary of the results of the questionnaires is in Appendix 2.

The draft recommendations were then discussed at the following five multi-stakeholder consultation meetings:

  • Prince George - October 11, 2006.
  • Edmonton - October 31, 2006.
  • Québec City - November 28, 2006.
  • Moncton - December 12, 2006.
  • Thunderbay - January 24, 2007.

The FTSR team encouraged interested stakeholders to send related comments or concerns to the team. All matters presented before February 15, 2007 were considered for inclusion in the final recommendations. Comments will continue to be welcome during the implementation stage of the FTSR.

1.7 Decision Making Criteria

Throughout the consultation process, the team has strived to achieve a consensus among sector stakeholders for all recommendations. The following conditions were used to guide the discussions:

  • general consensus of the vulnerable parties1 must support all recommendations;
  • general agreement from all stakeholders on all recommendations; individual dissenting opinions were captured;
  • general support from third parties (those who are not parties to the trade transaction);
  • all decisions/recommendations must be in line with Measurement Canada’s strategic direction;
  • all recommendations must be sustainable into the future;
  • the recommendations must be both practical and feasible and they must not deviate from international metrology standards in a manner that they could be construed as a barrier to international or North American trade agreements.

The following term has been used to describe the introduction of recommendations in this report:

Consensus - general stakeholder agreement and the vulnerable parties are in complete agreement with the recommendation(s). Complete agreement of all stakeholders is not required. Stakeholders who opposed the recommendation have had their opinion noted.

1A vulnerable party is the purchaser or seller of a product that does not own or control the measurement equipment used in the transaction. The degree of vulnerability may vary from nil to high depending upon the capacity and ability of the vulnerable party to detect measurement errors, re-measure the product and have corrective measures taken where appropriate.

1.8 Impact of Recommendations on Other Trade Sector Reviews

Some recommendations contained within this report may impact on other trade sector reviews. This report may be reviewed and possibly considered by other trade sector reviews for adoption, however, the recommendations in this report remain applicable only to the forestry sector.

1.9 Stakeholder Reach

The forestry review team has tried to ensure that the stakeholders who provided input or participated in the consultation meetings were representative of the sector. It was deemed essential to have the input of the vulnerable parties to the trade transaction and all viewpoints and comments were taken into consideration when deciding upon the recommendations.

Individual consumer input was not actively solicited for this trade sector review. Consumer input from previous trade sector reviews has indicated an admitted lack of technical knowledge in trade measurement and a preference for national standards, traceability of physical standards, approval requirements, initial and periodic inspections. In the firewood sub-sector, where individual consumers are heavily involved in trade, historical information has shown that device accuracy is not the issue when measurement concerns are investigated.

Representation from the sector included:

  • logging truck associations;
  • private woodlot owners;
  • federal government departments;
  • forest industry associations;
  • log truck operators;
  • forest industry engineering consultants;
  • provincial and territorial government agencies;
  • device manufacturers;
  • device service companies, including authorised service providers;
  • forestry equipment suppliers;
  • sawmill operators;
  • forest workers;
  • pulp and paper companies;
  • firewood dealers and consumers.

1.10 Acknowledgements

The FTSR team would like to express their appreciation to the stakeholders who participated in this process, particularly the two hundred and sixty two stakeholders who took the time to complete the questionaries and submit them. The team would also like to thank the sixty two stakeholders who made the effort to participate in the consensus meetings.

The team is satisfied that it has consulted with a sufficient number of sector stakeholders in order to solicit their opinion on what is the appropriate level of Measurement Canada intervention in the forestry trade sector. The FTSR team welcomes any comments, questions or clarifications on the content of this report.

The FTSR team would also like to thank their colleagues in Measurement Canada for both their support and the information provided during the project. The team is pleased to submit this report and encourages Measurement Canada’s Senior Management Committee (SMC) to accept the report’s recommendations.

The team would like to acknowledge the team stewards, Gilles Vinet and Sonia Roussy for their guidance and support during the review.

Lastly, the team would like to thank Merv Ostapovich for his insight in the development of the stakeholder questionnaire, which turned out to be invaluable in getting input from vulnerable forestry stakeholders.

The FTSR team:

Jamie Curran
Jamie Curran
1-709-772-5525

Dean Madson
Dean Madson
1-250-490-9723

Naman Boodram
Naman Boodram
1-780-495-2491

Susan Parato
Susan Parato
1-905-662-5900

Louis Martinet
Louis Martinet
1-819-763-6706

Sam Stouros
Sam Stouros
1-613-952-2627

2.0 Acronyms

A list of acronyms used in this document is provided below for the reader’s reference.

ASP - Authorized Service Provider
BIMP - Bureau International des Poids et Mesures
FTSR - Forestry Trade Sector Review
ISD - Innovative Services Directorate (Measurement Canada)
ISO - International Standards Organization
MBO - Marketing and Business Operations (Measurement Canada)
MC - Measurement Canada
NIST - National Institute of Standards and Technology (U.S.)
NRC - National Research Council (Canada)
OIML - Organization internationale de la métrologie légale
PDD - Program Development Directorate (Measurement Canada)
SA-01 - Measurement Canada’s Accreditation Standard
TSR - Trade Sector Review

3.0 Summary of Recommendations

3.1 Forest Industry Sub-Sector

(The following recommendations exclude retail firewood)

Approvals

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada continue to require type approval of scales used in forestry trade measurement (truck/vehicle scales, track/train scales, bunk scales, crane scales and platform scales including scales used to determine the moisture content of wood and wood chips). All other forestry trade devices are to be exempt, including but not limited to scaling sticks, tree calipers, moisture meters (probe type), measuring tapes, prisms, clinometers, gravitational positioning systems (GPS), reloscopes, hypsometers, thread meters, buoyancy devices.

2. Measurement Canada work with this sub-sector to implement their own metrological control process for linear devices such as scaling sticks, tree calipers and measuring tapes.

3. Measurement Canada expand mutual acceptance arrangements with other countries for approval testing.

4. Measurement Canada recognize other countries’ type approval processes, provided a formal evaluation process is implemented and the final approval of type remains with Measurement Canada.

Initial Inspections

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada continue to require scales, of all types, to be initially inspected.

2. Measurement Canada exempt all other trade measurement devices, used in this sub-sector, from initial inspection, but work with this sub-sector to implement their own metrological control process for trade devices, such as scaling sticks and tree calipers.

3. Organizations other than Measurement Canada be allowed to perform initial inspections provided they are authorized under the Measurement Canada accreditation or registration program.

4. A certificate be provided to device owners and an indicator affixed to devices, upon passing initial inspection, showing the date of the inspection certificate and the date the inspection certificate expires.

Periodic inspections

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada require scales, of all types, to be inspected annually. This recommendation also applies to scales used for pre-packaged commodities that are not currently exempt from inspection requirements. All other forestry trade devices to be exempt from periodic inspection.

2. Tolerances, for periodic inspections, continue to be as per the Weights and Measures Act and Regulations in the short term, but that tolerances be aligned, where possible, to International Organization for Legal Metrology requirements, within the next ten years.

3. Measurement Canada exempt linear measures, such as scaling sticks and tree calipers from periodic inspection, but work with this sub-sector to implement their own metrological control process for these devices.

4. Periodic inspections be performed by authorized service providers, provided they meet the established requirements of either the Measurement Canada accreditation or registration program.

5. A voluntary program for periodic inspection be implemented for periodic inspection, until legislative changes can be made.

Legislation

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada retain overall responsibility for forestry device legislation as provided in the Weights and Measures Act and Regulations.

2. Measurement Canada’s requirements affecting forestry devices remain uniform for all provinces and territories of Canada.

3. Measurement Canada work with industry in an effort to harmonize requirements with international standards, where possible.

4. Moisture measuring devices (other than scale types) be excluded from Measurement Canada requirements.

5. Measurement Canada work with Provincial and Territorial governments to remove any duplicate or excessive trade measurement regulations.

Physical Standards

A consensus of stakeholders and the FTSR team recommend that:

1. Users be responsible to ensure test standards, used to inspect scales, are calibrated and have a valid certificate of calibration. Measurement Canada to retain overall responsibility to monitor and perform enforcement actions, when necessary.

2. Measurement Canada extend its alternative service delivery programs to include the calibration of standards used in the forestry sector.

3. Measurement Canada work with this sub-sector to implement their own process for metrological control of linear measures, such as scaling sticks, tree calipers and tape measures.

4. Measurement Canada continue to pursue the recognition of other international standards laboratories.

Complaints

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada continue to provide complaint investigation and inspection services for this sector, but only after the two parties have had the opportunity to resolve the issue first.

2. Measurement Canada’s role as an unbiased third party to resolve complaints on device accuracy be better known among sellers and purchasers of forestry products.

3. Measurement Canada’s legislation allow for the full disclosure of complaint inspection information to the two parties of the transaction.

4. Measurement Canada’s legislation include powers to issue fines for repeated non-compliance.

Marketplace Monitoring

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada ensure that all stages of any future Forestry Trade Sector Review take place with the participation of vulnerable parties.

2. Measurement Canada collect compliance data on forestry devices and commodities and disseminate this information on a yearly basis to a registry of interested forestry stakeholders in aggregate form.

3.2 Retail Firewood Sub-Sector

The following recommendations exclude the above forest industry sub-sector. Wholesale firewood trade is to be considered included in the forestry sub-sector as transactions at this level of trade are predominantly performed via truck/vehicle scales.

The final recommendations in this sub-sector were achieved by sending an information bulletin containing draft recommendations to one hundred and twenty firewood stakeholders identified by the FTSR team. The final recommendations are based on the input from firewood stakeholders contacted in the initial phase of the review and the twenty three responses received from the bulletin mail out.

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada exempt retail firewood sub-sector devices (measuring tapes) from approval.

2. There be no requirements for initial inspection and periodic inspection of devices (measuring tapes) that are used in trade transactions of volume sales of firewood in Canada.

3. Measurement Canada require firewood dealers to provide a written disclosure of the volume of firewood being sold in either cubic feet or cubic meters.

4. Measurement Canada continue to investigate firewood complaints, educate buyers and sellers of the legal units of measure and have the power to fine repeat offenders.

4.0 Forest Sub-Sector Recommendations (Detailed)

4.1 Approvals

Background

Before a device can be used in trade in Canada, a prototype must receive approval from the Measurement Canada Approval Services Laboratory, located in Ottawa. The purpose of this approval is to ensure that a device is capable of measuring accurately under various conditions The approval process involves the evaluation of one or more devices of a particular type in accordance with the relevant regulations and specifications for design, composition, construction and performance. The sample device(s) are subjected to comprehensive testing at conditions which simulate the environment in which they are intended to operate. Once it has been determined that the instrument type complies with all specified approval requirements, pattern approval is granted and a notice of approval is issued.

Current

Measurement Canada legislation currently requires devices used in the forest industry to be approved. Most industrialized countries of the world require some type of approval process for trade measurement devices used in the forest industry.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada continue to require type approval of scales used in forestry trade measurement (truck/vehicle scales, track/train scales, bunk scales, crane scales and platform scales including scales used to determine the moisture content of wood and wood chips). All other forestry trade devices are to be exempt, including but not limited to scaling sticks, tree calipers, moisture meters (probe type), measuring tapes, prisms, clinometers, gravitational positioning systems (GPS), reloscopes, hypsometers, thread meters, buoyancy devices.

2. Measurement Canada work with this sub-sector to implement their own metrological control process for linear devices such as scaling sticks, tree calipers and measuring tapes.

3. Measurement Canada expand mutual acceptance arrangements with other countries for approval testing.

4. Measurement Canada recognize other countries’ type approval processes, provided a formal evaluation process is implemented and the final approval of type remains with Measurement Canada.

Key Considerations

Stakeholders indicated that Measurement Canada should not necessarily be the only device approval laboratory that conducts approval testing. Other authorized laboratories could be acceptable if they meet the established standard. Measurement Canada oversight would be required and Measurement Canada would be the organization that would make the final decision as to whether or not a given forestry device receives an approval for use in trade in Canada. Only Measurement Canada would have the authority to grant an approval.

Approval testing or evaluation in other jurisdictions be considered if the method of testing or method of evaluating meets the established requirements.

Measurement Canada will need to amend section 4 of the Weights and Measures Regulations to state the exemption for specific forest sector devices.

Rationale

A consensus of stakeholders agreed that a device type approval program should continue for scales to ensure that only high quality devices will be used in trade applications.

Acceptance of approval testing results from other organization or other jurisdictions may shorten the time it takes for some devices to receive approval. It may also reduce the cost of the obtaining the notice of approval for the device approval applicant.

Implementation

Priority: High

Time line: Short Term (1 to 2 years) - Measurement Canada to make the regulation changes to exempt static/linear measures (scaling sticks, tree calipers, measuring tapes) used in the forest sector from approval.

Long Term (5 to 10 years) - Measurement Canada to expand the use of formal programs to evaluate and recognize approval testing performed by other organizations or jurisdictions.

Responsibility Centre:

ISD for work on mutual recognition arrangements.

PDD for the work on having the Regulations amended.

4.2 Initial Inspections

Background

Unless exempt under the Weights and Measures Regulations, a device intended to be used in trade must be approved and be initially inspected by a Measurement Canada inspector or Authorized Service Provider (ASP). This inspection ensures that devices are properly configured and calibrated before being used. The device must operate within the appropriate limits of error as prescribed by the Weights and Measures Act and Regulations or applicable specifications.

Depending on the complexity of the device, this inspection may take place at the manufacturer’s premise, service company shop or on-site after installation. Inspection results will determine if the instrument is certified for use or not. If the device meets requirements a verification indicator is placed on the certified device by either Measurement Canada or an authorized service provider.

Current

Current legislation requires all devices used in the forestry industry to pass an initial inspection prior to being used in trade. There are limits of error prescribed in the Weights and Measures Act and Regulations. Forestry devices are tested at either the device manufacturer’s test facilities before they are sold or at their installed location.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada continue to require scales, of all types, to be initially inspected.

2. Measurement Canada exempt all other trade measurement devices, used in this sub-sector, from initial inspection, but work with this sub-sector to implement their own metrological control process for trade devices, such as scaling sticks and tree calipers.

3. Organizations other than Measurement Canada be allowed to perform initial inspections provided they are authorized under the Measurement Canada accreditation or registration program.

4. A certificate be provided to device owners and an indicator affixed to devices, upon passing initial inspection, showing the date of the inspection certificate and the date the inspection certificate expires.

Key considerations

Measurement Canada will need to amend the Weights and Measures Regulations as it applies to static measures.

Rationale

Static measures such as scaling sticks, tree calipers and measuring tapes are used in the forest sub-sector in the measurement of standing trees and cut logs. Few final trade transactions occur using only these devices. Most final trade transactions in this sub-sector occur using measurements from a scale of one type or another.

All stakeholders who participated in the FTSR process, agree that a mandatory initial inspection program be continued for all scale types. This should ensure that only accurate measuring devices will be put into service.

The majority of stakeholders agreed that mandatory initial inspections should not be required for static measures, such as scaling sticks and tree calipers however, stakeholders indicated they would like Measurement Canada to work with the industry to establish a national standard practice for ensuring static measures are accurate upon receipt from manufacturers. Canadian Standards Association document CSA 0302.1-00/0302.2-00 contains limits of error requirements for scaling sticks and tree calipers. This document is in use in many provincial jurisdictions in Canada, however its use is not mandatory in all provinces and territories.

Implementation

Priority: High

Time line: Short Term (1 to 2 years) - Measurement Canada to expand the scope of the accreditation and registration program to recognize organizations who will have the authority to conduct forestry device initial inspections.

Short Term (1 to 2 years) - Measurement Canada to exempt static measures, used in the forest industry, from mandatory initial inspections and require indicators to contain the certificate inspection date and certificate expiration date.

Responsibility Centre:

ISD to expand the accreditation and registration programs to include scales used in the forest industry sub-sector.

PDD to exempt all trade devices, other than scales, in this sub-sector and update requirements to include the certificate inspection date and certificate expiration date.

PDD to create a working group with this sub-sector to establish their own metrological control process for static measures.

4.3 Periodic Inspections

Background

Measurement Canada inspects weighing and measuring devices throughout their service lifetime to ensure they continue to measure accurately and are not used in a fraudulent manner. Appropriate corrective action is initiated for those measuring instruments which are not in compliance with the appropriate regulations and specifications. Currently, there are no prescribed mandatory requirements for the periodic inspection of weighing and measuring devices in the Weights and Measures Act and Regulations. Measurement Canada inspections are based on priorities and available resources.

It should be noted that trade sector reviews in other sectors have included recommendations to establish mandatory periodic inspections.

Current

The Weights and Measures Act and Regulations does not exempt any forestry devices from the requirement to be approved and initially inspected before being used in trade. Under the current legislation:

There are no provisions that specifically exempts static measures used in the forest industry from inspections. Measurement Canada has not made it a practice to inspect these devices due to the small number of complaints received in this area.

There are no requirements for forestry devices to be inspected after the initial inspection. It is the responsibility of the device owners to maintain their devices in compliance with the Weights and Measures Act.

There are limits of error for devices prescribed in the Weights and Measures Act and Regulations.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada require scales, of all types, to be inspected annually. This recommendation also applies to scales used for pre-packaged commodities that are not currently exempt from inspection requirements. All other forestry trade devices to be exempt from periodic inspection.

2. Tolerances, for periodic inspections, continue to be as per the Weights and Measures Act and Regulations in the short term, but that tolerances be aligned, where possible, to International Organization for Legal Metrology requirements, within the next ten years.

3. Measurement Canada exempt linear measures, such as scaling sticks and tree calipers from periodic inspection, but work with this sub-sector to implement their own metrological control process for these devices.

4. Periodic inspections be performed by authorized service providers, provided they meet the established requirements of either the Measurement Canada accreditation or registration program.

5. A voluntary program for periodic inspection be implemented for periodic inspection, until legislative changes can be made.

Key Considerations

An overlying concern with periodic inspection requirements is the cost to device owners. In many cases, owners are calibrating their scales on a regular basis via service contracts, either quarterly or semi-annually. For the most part, calibrations being done are not as extensive as what is required for a Measurement Canada inspection. Stakeholders will still need to continue to perform maintenance calibrations to ensure devices remain accurate between inspections.

The time interval for periodic inspections should be revisited as compliance rates improve.

Some stakeholders requested that device tolerances be commodity price based. Lower value commodities would receive less stringent tolerances. (Note: Current Measurement Canada requirements allow for alternate scale configurations to address low value commodities. Interested stakeholders should contact the Measurement Canada regional gravimetric specialist in regards to this option.)

The implementation of mandatory inspections could result in device owners reducing maintenance calibration work to the legislated inspection periods, creating a lower compliance rate than currently exists. Measurement Canada will need to inform device owners of the need to continue to perform regular maintenance between mandatory inspections.

Although stakeholder questionnaires indicated an annual periodic inspection or more, at the consensus meetings many stakeholders indicated they would prefer a two year periodic inspection period. This appeared to be as a result of the device owners becoming aware that they would be paying an authorized service provider’s inspection at market value rather than inspection at Measurement Canada inspection rates.

Stakeholders expressed concern with the need to have full or maximum capacity tests done during periodic inspections of truck/vehicle scales.

Changes to legislation will be required to introduce requirements for the mandatory periodic inspection of forestry scales in Canada. Changes may also be needed to identify the forestry devices types exempt from periodic inspection.

Rationale

The vast majority of stakeholder, who participated in the FTSR process, agree that a mandatory periodic inspection program should be established. The final recommendation was based on the input from vulnerable parties at the consensus meetings and from the support for a one year periodic inspection period from stakeholder questionnaires.

Some stakeholders felt that forestry devices should not be required to have a mandatory periodic inspection period. Others said that mandatory inspections should not be required for those devices being calibrated on a regular (at least semi annual) basis using calibrated standards. Other options and opinions that were put forward and discussed during the FTSR process include:

Reduce periodic inspections in recognition of service contract calibration work being performed on a regular basis.

Authorize provincial authorities to perform device inspections on Measurement Canada’s behalf.

The financial impact concern that mandatory periodic inspections could have on forestry companies who own scales in remote locations.

Authorized service companies may be in short supply in remote areas and the few that are available could charge higher than normal fees.

Implementation

Priority: High

Time line: Short Term (1 to 2 years) - Measurement Canada expand the scope of the accreditation and registration program and authorize organizations to perform periodic inspections of forestry devices (scales) on a voluntary basis.

Medium Term (2 to 5 years) - Measurement Canada to implement the necessary legislative reform to mandate periodic inspection of specific forestry devices.

Responsibility Centre:

ISD for expanding the accreditation and registration program to include periodic inspection of forestry scales.

PDD for making the legislative changes to require mandatory periodic inspections.

4.4 Legislation

Background

Measurement Canada

Under Section 91, subject 17, of the Constitution Act of Canada, the exclusive legislative authority of the Parliament of Canada extends to all matters coming within the subject of Weights and Measures.

Current

The Weights and Measures Act and Regulations currently requires forestry devices to be type approved and be initially inspected before being used in trade. There are also limits of error and inspection procedures established for forestry devices.

Canada is a participating member of the International Organization of Legal Metrology (OIML). This organization develops and maintains international standards for a multitude of weighing and measuring devices. OIML has developed a recommended standard ®-76). Similarly, the United States model laws are set out in NIST Handbook 44 and Handbook 133. These laws are often adopted by individual states as mandatory requirements for their respective State.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada retain overall responsibility for forestry device legislation as provided in the Weights and Measures Act and Regulations.

2. Measurement Canada’s requirements affecting forestry devices remain uniform for all provinces and territories of Canada.

3. Measurement Canada work with industry in an effort to harmonize requirements with international standards, where possible.

4. Moisture measuring devices (other than scale types) be excluded from Measurement Canada requirements.

5. Measurement Canada work with Provincial and Territorial governments to remove any duplicate or excessive trade measurement regulations.

Key Considerations

Some stakeholders suggested that Measurement Canada requirements take into consideration the relatively low cost of wood in determining device limits of error.

Measurement Canada will have to ensure all stakeholders in the forestry industry are made aware of any new regulatory requirements for forestry devices in Canada.

Rationale

The overwhelming majority of stakeholders, who participated in the FTSR process, agree that Measurement Canada should establish mandatory periodic inspections for scales type devices used in the forest industry in Canada. The adoption of this requirement should ensure accurate trade measurement in the forestry trade sector.

Most stakeholders expressed the belief that static measures should be unregulated and the testing of static measures such as scaling sticks, tree calipers and measuring tapes be performed by the individual device owners on a voluntary/best practices basis, but that Measurement Canada be involved to help ensure the devices are accurate upon receipt from suppliers.

Implementation

Priority: High

Time line: Long Term (2 to 5 years) - Measurement Canada implement the necessary legislative reform for the use of mandatary periodic inspection of forestry devices in Canada.

Responsibility Centre:

PDD for regulatory changes and for initiating work with the forest industry to establish their own requirements for static measures.

4.5 Physical Standards

Background

Measurement Canada

Any test standard used by a Measurement Canada inspector or Measurement Canada Authorized Service Provider to certify devices under the Weights and Measures Act and Regulations or Electricity and Gas Inspection Act and Regulations must be calibrated and certified by Measurement Canada. This requirement applies to test standards owned by an Authorized Service Provider or Measurement Canada.

Current

There are mandatory calibration and certification requirements for physical standards used by Measurement Canada or Authorised Service Provider.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Users be responsible to ensure test standards, used to inspect scales, are calibrated and have a valid certificate of calibration. Measurement Canada to retain overall responsibility to monitor and perform enforcement actions, when necessary.

2. Measurement Canada extend its alternative service delivery programs to include the calibration of standards used in the forestry sector.

3. Measurement Canada work with this sub-sector to implement their own process for metrological control of linear measures, such as scaling sticks, tree calipers and tape measures.

4. Measurement Canada continue to pursue the recognition of other international standards laboratories.

Key Considerations

At this time, few companies have expressed interest in certifying test standards or test equipment. Measurement Canada continues to be the primary source of test standard and test equipment certifications.

Measurement Canada should consider recognizing physical standards which have been certified with standards traceable to the National Institute for Science and Technology (NIST) in the United States of America. Similar consideration should be given to physical standards certified in other jurisdictions if they have been certified with standards that are traceable to the Bureau International des Poids et Mesures (BIMP) and they have procedures in place to ensure proper certifications.

Rationale

Physical measurement standards that are reliable, accurate and traceable to National Research Council (NRC) or international (NIST) or (BIPM) standards are the basis for any sound metrological control program. Any significant uncertainties or calibration errors impact directly on trade measuring device accuracy. Even small inaccuracies may result in significant financial loss for the participants in the trade transaction. It is vital that rules for measurement standards are established and applied.

In order to have a uniform, reliable, national measurement system, uncertainties of standards must be established. Standards must be maintained and used in accordance with sound procedures and must be suitable for the intended use. Stakeholders feel that Measurement Canada is in the best position, with the necessary authority, to accomplish this goal for the forestry trade sector.

Laboratories with acceptable procedures and reference standards that have an unbroken traceability to recognized national standards may provide the same level of reliability and accuracy as the calibration done by Measurement Canada.

Implementation

Priority: Medium

Time line: Long Term (2 to 5 years) - Measurement Canada to change the legislation to allow for traceability to other national and international standards.

Responsibility Centre:

ISD to expand its alternative service delivery calibration program to include physical standards used to inspect forestry devices.

PDD to form a working group with the forest industry sub-sector for linear measurement standards.

4.6 Complaints

Background

Buyers or sellers of goods or services who suspect they have received inaccurate measurement and who have been unable to resolve their concern with the other party to the transaction may contact the nearest Measurement Canada office and request that their complaint be investigated. Complaint investigations may include:

  • investigation
  • device inspection
  • net quantity verification of pre-packaged goods such as wood chips
  • test purchases or test sales of a product or service
  • trader education

Current

Measurement Canada customarily investigates forestry device complaints. In the past, local Measurement Canada offices have received a small number of complaints regarding forestry devices such as scales. However seasonally, Measurement Canada receives numerous complaints about firewood.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada continue to provide complaint investigation and inspection services for this sector, but only after the two parties have had the opportunity to resolve the issue first.

2. Measurement Canada’s role as an unbiased third party to resolve complaints on device accuracy be better known among sellers and purchasers of forestry products.

3. Measurement Canada’s legislation allow for the full disclosure of complaint inspection information to the two parties of the transaction.

4. Measurement Canada’s legislation include powers to issue fines for repeated non-compliance.

Key Considerations

Stakeholders feel that Measurement Canada should consider the low cost of wood products when they establish limits of error for the inspection of a forestry devices that are subject of a customer complaint.

At least one stakeholder indicated that they were uncomfortable with having Measurement Canada disclose complaint inspection information to all parties.

Rationale

Measurement Canada’s mandate and strategic direction is to remain involved in the investigation of complaints that cannot be resolved by the parties to a trade transaction. As a minimum, Measurement Canada will provide technical advice and /or inspection services that could lead to a resolution. As the third party arbiter of any forestry device complaint, Measurement Canada should be viewed as being totally independent by all parties to the trade transaction.

This recommended level of Measurement Canada intervention in forestry device complaints should give the disputing parties a neutral investigative ruling which can be used in cases where measurement disagreements cannot be resolved by current means.

Implementation

Priority: High

Time line: Medium Term (2 to 3 years) - Measurement Canada to develop the necessary requirements in regards to the disclosure of complaint inspection information.

Long Term (3 to 5 years) - to change the legislation to allow Measurement Canada to issue fines for repeated non-compliance.

Responsibility Centre:

PDD to make regulatory changes to allow for complaint inspection disclosure and to issue fines for repeated non-compliance.

MBO to implement a communication strategy to educate forestry stakeholders about Measurement Canada’s role in complaint investigations.

4.7 Marketplace Monitoring

Background

Measurement Canada’s strategic direction is to monitor compliance within the marketplace to ensure that established levels of intervention are adequate to maintain stakeholder confidence. To facilitate this, Measurement Canada will need to establish performance indicators to measure sector compliance. Historically, performance indicators were mainly compliance rates for device and commodity inspections. These rates were determined from results obtained by Measurement Canada inspectors during initial inspections and periodic inspection cycles. Due to resource limitations, Measurement Canada has been inspecting fewer and fewer forestry devices over the last few years.

Measurement Canada may choose to conduct future follow-up sector reviews of the forestry trade sector should marketplace monitoring raise major concerns. The purpose of these reviews would be to ensure that any implemented programs continue to meet the needs of all stakeholders. These follow-up reviews would be similar to the one presently being conducted but probably much narrower in scope and of far shorter duration. The follow-up review would be in addition to ongoing monitoring.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada ensure that all stages of any future Forestry Trade Sector Review take place with the participation of vulnerable parties.

2. Measurement Canada collect compliance data on forestry devices and commodities and disseminate this information on a yearly basis to a registry of interested forestry stakeholders in aggregate form.

Key Considerations

Measurement Canada will establish key indicators to be used in the ongoing marketplace monitoring of the forestry trade sector. These key indicators will be developed during the implementation stage of the FTSR and stakeholders will be consulted.

Concerns were expressed by stakeholders regarding whether Measurement Canada would have the resources to conduct sufficient monitoring.

Rationale

Measurement Canada needs to have mechanisms in place to ensure that the programs resulting from the trade sector review are working effectively and to determine if the needs of the stakeholders and Measurement Canada are being met.

It is important for Measurement Canada to keep the stakeholders aware of the state of trade measurement in the forestry trade sector and keep them advised of the effectiveness of the implemented programs. Measurement Canada must be careful not to publish information that could damage the reputation of stakeholders.

Implementation

Priority: Medium

Time line: Medium Term (2 to 3 years) to develop the necessary policies and procedures needed for monitoring the forestry trade sector marketplace.

Responsibility Centre:

PDD to collect compliance data and disseminate the information to forestry stakeholders and to ensure future forestry sector reviews, include vulnerable parties.

5.0 Retail Firewood Sub-Sector Recommendations (Detailed)

Background

Traditionally, Measurement Canada has not been involved in the inspection of static measures used in the firewood sub-sector, however, Measurement Canada has responded to numerous seasonal consumer complaints about firewood. Investigations have revealed that the measurement device is rarely an issue, but rather the understanding and use of the legal unit of measure “cord of wood”.

Current

The practice of selling firewood by non-legal units, such as the cordon, stove cord, bush cord, etc. is still prevalent in parts of Canada, predominately in central and eastern regions. Buyers as well as sellers use arbitrary units of measure to describe what is wanted or what is for sale, with the consumer expecting a legal cord (128 cubic feet) and receiving less than that.

Recommendations

A consensus of stakeholders and the FTSR team recommend that:

1. Measurement Canada exempt retail firewood sub-sector devices (measuring tapes) from approval.

2. There be no requirements for initial inspection and periodic inspection of devices (measuring tapes) that are used in trade transactions of volume sales of firewood in Canada.

3. Measurement Canada require firewood dealers to provide a written disclosure of the volume of firewood being sold in either cubic feet or cubic meters.

4. Measurement Canada continue to investigate firewood complaints, educate buyers and sellers of the legal units of measure and have the power to fine repeat offenders.

Key Considerations

Measurement Canada will need to work with provincial authorities and firewood dealers to educate them on the legal units of measure and how to apply the requirements to establish and maintain confidence in the marketplace.

Measurement Canada will need to have the legislation in place and the resources available to issue fines when repeated non-compliance occurs.

Implementation

Priority: Medium

Time line: Medium Term (2 to 4 years) to establish the necessary regulations and procedural changes to implement the recommendations above.

Responsibility Centre:

PDD for the regulatory changes and to initiate a firewood industry working group to establish their own national code of ethics.

MBO to implement a communications strategy to educate dealers and the public about the requirements.

Appendix 1 - Registered Stakeholders

Over 500 individuals and organizations were contacted for input during the forestry sector review process and offered the opportunity to register as a stakeholder; 342 registered. By registering, stakeholders were provided information such as the discussion paper containing the results of the questionnaire and the draft recommendations. Registered stakeholders also received information on the locations of the regional consensus meetings and information about how to get a copy of this report.

The FTSR team made every effort to ensure that a cross-section of stakeholders were contacted including vulnerable parties.

The following is a list of organizations in alphabetical order that registered for the Forestry Trade Sector Review:

Abitibi Consolidated
Abitibi Consolidated Company of Canada
Abitibi-Consolidated du Canada Compagnie
Abitibi-Consolidated-Secteur Comtois
Acadian Timber
Accurate Scale Industries Ltd.
Accurate/Western Scale Co. Ltd.
Active Scale Manufacturing Inc.
Adams Lake Lumber
Ainsworth Engineered Canada LP
Alberta Board Company Ltd.
Alberta Government
Alberta Newsprint Company
Alberta Plywood Ltd.
Alberta-Pacific Forest Industries Inc
Alectronic Scale
Ancoma Scales
APA Engineered Wood Association
Armand Duhamel et fils
Association coopérative de travail
Association des mesureurs de bois licenciés du Québec
Athol Forestry Cooperative Limited
Atlantic Provinces Trucking Association
AV Cell
B.A.Fraser Lumber Ltd.
Baddeck Valley Woodproducers Co-op Ltd
Balances Experts inc
Balances M. Dodier inc
Balances Universelles Inc.
BAP Equipment
Barrett Lumber Co. Ltd
Barrette-Chapais Ltée
Bay Lumber Limited
BC Ministry of Forests & Range
Boisaco Inc.
Boniferro Mill Works Inc.
Bowater
Bowater Canadian Forest Products Inc.
Bowater Forest Products Division
Bowater Maritimes
Bowater Newsprint
Bowater produits forestiers du Canada Inc.
Bowater Sawmill
Buchanan Forest Products
Buchanan Lumber
Bulldog Scale Co Ltd
Calgary Scale Services (1988) Ltd.
Canadian Forest Products
Canadian Manufactured Housing Institute
Canadian Pacific Railway
Canadian Pallett Council
Canadian Paperboard Packaging Association
Canadian Scale Company
Canfor
Cascadia & Island Timberlands
Cedrico Inc., Bois d'oeuvre
Central Interior Logging Association
Centre de Récupération Perron inc.
Centre de service en réseau d'entreprise
Centre Jardin Doyon Inc
Chee-Bee Construction Wood Products
CLERAL
Cleral inc.
Coastland Wood
Coastlandwood Ind.
Commonwealth Plywood Co. Ltd.
Conform Limited
Conseil de l'industrie forestiere du Quebec
Cooperative Agro-forestière Beaucanton
Cooperative de travail de Guyenne
Coopérative de Travali Abitibi Centre (Tanguay, France)
Coopérative Forestière de Petite Nation
Coopérative forestière des Hautes-Laurentides
Coopérative Forestière du Nord-Ouest
Corner Brook Pulp & Paper
Cottles Island Lumber Co. Ltd.
Council of Forest Industries
Crête (Gérard) & Fils Inc.
Cross-Cut Silvics LTD.
Daishowa-Marubeni, Peace River Pulp Division
Dendrotik Inc.
Desna Controls & Weighing Inc.
Domtar
Domtar inc
Domtar Inc. Div. Lebel-Sur-Quévillon
Domtar, Division Matagami
East Kootenay Log Haulers Association
Echo Bay Scaling &Grading Inc.
Elmira Wood Products Ltd.
Embellissements M.Fraser
Environment and Natural Resources; Forest Management; GNWT
Eurocan Pulp & Paper
Evergreen Lumber Inc.
Every Scale Ltd.
EXACT MODUS (Canada)
Excel Transportation Inc.
F.F. Soucy Inc.
Federation of BC Woodlot Associations
Federation of NS Woodland Owners
Flakeboard Co. Ltd.
Fleetway Facility Services
Folly Mountain Hardwoods
Footner Forest Products Ltd.
Forest Products Association of Canada
Forest Products Association of Nova Scotia
Foresterie BRN senc
Galloway Lumber
Garden River Logging Co. (1988) Ltd.
Garrett Log Service
GDS inc., Groupe de scieries
Glen Transport
Groupe Savoie
Hansen Forest Products Ltd.
Harry Freeman & Son Ltd.
Herb Shaw & Sons Ltd.
Hi-Tech Scales
Industrial Forest Service Ltd.
Industrial Scale Ltd.
Industries manufacturières Mégantic Inc.
INFOR
Inspec-Tech Inc.
Interfor
Interior logging Association
International Woodworkers Association
Irving Forest
Irving Paper
Island Scale
J. D. Irving Limited
J.D.Irving (Sussex)
Jacques Pagé bois de foyer enr.
JD Irving Ltd.
JD Irving(Sproule)
Kalesnikoff Lumber
Kelly Ranch Ltd.
Keywood Recovery Inc.
Krahn Logging
Kruger Inc.
Kruger
KW Brant Scale
LaCrete Sawmill Ltd
Leduc, Scierie/Div. de Stadacona Inc.
Les Balances Leduc & Thibeault Inc.
Les Chantiers Chibougameau Ltée
Lomak Transportation
Louisiana-Pacific Canada Ltd
Lulumco Inc.
Lumber & Building Materials Association of Ontario
MacTara
Maibec
Manitoba Conservation
Manning Diversified Forest Products Ltd.
Marathon Pulp Inc.
Maritime Lumber Bureau
Marshall Lumber Mill
Matériaux Blanchet inc.
McLean Scale Company Ltd.
Metric Cal Scaling
Mettler Toledo
Mettler Toledo Inc.
Min of Forests & Range
Ministère des Ressources naturelles et de la Faune
Ministry of Forests & Range
Ministry of Forests & range Kalum District
Monte Lake Forest Products Inc.
Mostowich Lumber Ltd.
National Lumber Grades Authority
NB DNR - Forest Management Branch
NB Federation of Woodlot Owners
NB Forest Products Association
Neenah Paper
Neucel Specialty Cellulose
NFLD Firewood
Nickel Lake Lumber
NL Dept of Natural Resources
NL Lumber Producers Association
Norbord Inc
North American Forest Products Ltd
North Atlantic Lumber
North Enderby Timber
North Nova Forest Owners Co-op Ltd.
North West Logging Association
Northern Scale
Northwestern Ontario Logging Transport Association
NS Dept. of Natural Resources
Olav Haavaldsrud Timber Co. Ltd.
Ontario Lumber Manufacturer's Association
Ontario Ministry of Environment
Ontario Ministry of Natural Resourses
Ontario Woodlot Association
Orillia Scale Service
Pacific Industrial Scale Co.
Papiers Fraser Inc.
Papiers P.S.T.
Paragon Wood Products
Pelletier Équipement Ltée/Ltd
Petit Paris Inc., Produits forestiers
Phoenix Forest Products
Pinnacle Pellet WL Inc.
Pioneer Scaling&Inventory Mgt. Ltd.
Pope & Talbot
Portelance Lumber
Portelance Lumber
Precision Giant Systems Inc.
Precut Hardwood Inc.
Produits forestiers Domtar inc.
Produits Forestiers Dubé Inc
Rapids Camp
BC Ministry of Forests and Range
Ridgeview Mills Ltd.
Right Weigh Scales Ltd.
Rocky Wood Preservers Ltd.
Sask Environment, Forest Service
Scale Shop
Scale Solutions Inc.
ScaleTech Systems Ltd.
Scierie Landrienne Inc.
Scierie Thomas-Louis Tremblay
SDN Contracting
Sexton Lumber
Skeena Sawmills
Smurfit-Stone
Spray Lake Sawmills
Springer Creek Forest Products
Squilax Timber & Supply Ltd.
St.Jean Lumber
Stella-Jones
Strong Engineering
Structural Board Association
Sundance Forest Industries Ltd
Sunshine Garden Center
Sutreen Hardwoods and Mouldings
Sylviculture MD
Systèmes b.c.b.f. Inc
Taylor Lumber Company Limited
TDB Consultants Inc
Tembec
Tembec Davidson inc
Tembec Forest Products
Tembec Forest Products Group
Tembec (France)
Tembec Inc. Division Senneterre
Tembec Industries Inc.
Tembec Industries Inc. GPF
Tembec Industries Skookumchuck Pulp Mill Operation
Tembec, Papiers spécialités et fins
Temlam (Amos) Inc.
Tolko Industries Ltd.
Tolko
Transport Boulet senc.
Truck Loggers Association
Unibek-Combubois
Uniboard Canada inc.
Uniboard Canada inc.
UPM - Kymmene Miramichi
US Tape Co., Inc. (USA)
Velcan Forest Products
Weigh-Tronix
Weight-Tronix Canada
West Fraser Mills Ltd.
West Fraser Plywood
West Island Nurseries
Western Canada Wood Products Ltd.
Western Forest Products
Western Professional Truck Driver Association
Western Scale Co. Ltd.
Weston Forest Group
Westwood Fibre Products Inc.
West-Wood Manufacturing Ltd
Weyerhaeuser
Weyerhaeuser Canada
Weyerhaeuser Cellulose Fibers
Weyerhaeuser Company Ltd.
Weyerhaeuser Forestlands
Weyerhaeuser Miramichi OSB
Wholesale Lumber Dealers Associations Inc.
Wood Products Group
Woodman Firewood Ltd
YSC Forest Products Marketing Board

Appendix 2 - Results from the Forestry Trade Sector Review Questionnaire

Part I - Stakeholder profile

Question i) With the exception of retail consumers all stakeholder groups were represented in the feedback received. The majority of feedback came from sawmills - 45.

Loggers - 12
Logging companies - 39
Saw mills - 45
Pulp and paper mills - 44
Wood manufacturers - 21
Wholesalers and distributors of processed wood products - 11
Transporter of raw or processed wood - 23
Wholesale and retail consumers (builders, construction) - 5
Device manufacturer - 6
Device service/repair company - 16
Federal agency - 0
Provincial agency - 9

Question ii) Stakeholders indicated the majority of devices they use for trade purposes are scales - 106.

scales - 106
measuring tapes - 56
calipers - 26
other , scale rules - 5, scaling sticks - 3
not applicable - 6

Question iia) Stakeholders indicated the majority of these devices are calibrated. Those that were calibrated are calibrated once per year.

Question iib) Stakeholder feedback indicated the majority of these devices meet specific accuracy requirements.

The majority of stakeholders indicated the requirements they meet are those in the Weights and Measures Act and Regulations.

Question iii) The majority of stakeholders indicated they use measurement to buy forest products -78.

to buy forest products - 78
to sell forest products - 59
to pay employees - 28
to pay transporters - 65
to package forest products - 11
other (contractor payment) - 4

Question iv) The majority of stakeholders indicated they are very satisfied with the level of measurement accuracy and equity in the forestry industry.

very satisfied - 62
Somewhat satisfied - 34
Somewhat dissatisfied - 13
very dissatisfied - 2

Question v) The majority of stakeholders indicated that when they believe they did not get what they paid for, because of incorrect measurement, they would complain and settle with the device owner.

complain to, and settle with the device owner - 31
complain to a provincial organization - 6
complain to a federal organization - 0
complain to Measurement Canada - 7
do nothing - 10
not applicable - 60

Question vi) The majority of stakeholders indicated they know or found out about Measurement Canada by having dealt with Measurement Canada directly for inspections - 76.

inspections - 76
approvals - 33
calibrations - 35
complaint - 9
information - 35
accreditation or registration - 24
other: From the website - 12, Telephone book - 5
Did not know about Measurement Canada at all - 14

Part II - Measurement Canada's Level of Involvement

Question 1 - Measurement Canada's Services

Feedback indicated the majority of stakeholders feel Measurement Canada services are needed for the calibration of test standards, approval of measurement devices, initial inspections and on going inspection.

Approval of measuring device types (eg. scale models) before they can be used in trade.- 87
Initial inspection of measuring devices (scales, etc. ) before they can be used in trade. - 83
On going inspection of devices that are used in trade - 83
Calibration of measurement standards (test weights) that are used to verify accuracy of measuring devices (scales). - 81
Net quantity verification (commodity inspection) of bulk or wholesale products - 20
None - 3
Don't know - 2

Question 2 - Measurement Standards

Feedback indicates the majority of stakeholders want measurement standards (eg. standard weights used for scales) to have a certificate of calibration issued by Measurement Canada or by an acceptable outside laboratory on behalf of Measurement Canada.

Have the design and construction of their model or type approved by Measurement Canada. - 49
Have a certificate of calibration issued by Measurement Canada only - 30
Have a certificate of calibration issued either by Measurement Canada or by an acceptable outside laboratory on Measurement Canada's behalf - 62

Have a certificate of calibration that is traceable to:
- a national standard (e.g. NRC (Canada) - 36
- an international standard (e.g. National Institute of Standards and Technology (USA), or International Organization for Legal Metrology) - 18

Be calibrated and certified every year.
6 months - 25
1 year - 38
2 years - 11
5 years - 16
None of the above, it should be left up to the industry - 7
Don't know - 14

Question 3 - Device (e.g. scales, measuring systems) Approvals

The majority of stakeholders indicated device types should continue to be tested for approval by Measurement Canada and have an approval for use in trade issued by Measurement Canada.

Continue to be tested for approval by Measurement Canada and have an approval for use in trade issued by Measurement Canada - 53
Have the approval testing done by an acceptable laboratory on Measurement Canada's behalf and have an approval for use in trade issued by Measurement Canada - 37
Have the approval testing done and an approval for use in trade issued by an acceptable laboratory on Measurement Canada's behalf - 42
Not need to be approved - 2
Don't know - 4

Question 4 Device (scales, measuring systems) Initial Inspections

The vast majority of stakeholders indicated they think measuring devices (scales, etc. ) should be initially inspected before being used in trade.

Be initially inspected before being used in trade - 112
Be used in trade without an initial inspection, only random inspections are needed - 6
Not be inspected at all - 1
Don't know - 1

Question 5 - Device (scales, measuring systems) Periodic Inspections

The majority of stakeholders indicated they think devices (scales, etc.), used in trade, be required to be periodically inspected every year.

6 months - 25
1 year - 52
2 years - 14
3 years - 1
4 years - 0
5 years - 0
no period, the inspections should be random as they are now - 39
Don't know - 0

Question 6 - Measuring Device Accuracy Maintenance

The majority of stakeholders that own measuring device (scale, etc. ) used in trade, ensure the device is calibrated and serviced by a service/repair company every 6 months or less.

Calibrated and serviced by a service/repair company every:
6 months or less - 43
1 year - 22
2 years - 2
(3 months - 1)

Inspected by an accredited company every:
6 months - 10
1 year - 16
2 years - 2
(3 months - 2)
Calibrated and serviced by a service/repair company whenever it is not working properly - 35
Wait for a Measurement Canada inspection and get it repaired by a service/repair company only if it fails the inspection - 7
Wait until there is a complaint - 2

Question 7 - Net Quantity Verification of Bulk or Wholesale Products

Feedback shows net quantity of products which are sold by measure (weight) for bulk or wholesale use be inspected by Measurement Canada annually.

Inspections by Measurement Canada every:
6 months - 8
1 year - 31
2 years - 6
5 years - 0
randomly, no period - 30
Inspection by another government agency such as the Canadian Food Inspection Agency - 9
The processors and packers or sellers should be responsible with the use of quality assurance or quality management systems - 15
There is no need to verify the net quantity, it should be left to the buyer and seller - 12
Don't know - 17

Question 8 - Accuracy of Bulk or Wholesale Products

The majority of manufacturers, processors or importers of bulk or wholesale products companies ensure that the net quantity measurements are accurate by having a quality assurance or quality control system in place and have the devices that are used for measuring products calibrated regularly.

Have a quality assurance or quality control system in place and have the devices that are used for measuring products calibrated regularly - 60
Wait for Measurement Canada inspectors to check products and inspect the devices used for measuring products - 4
Have no system to ensure the net quantity is accurate - 11

Question 9 - Complaint Investigation

Feedback indicates the majority of stakeholders want the complaint investigated by Measurement Canada, the inspection results provided to the complainant and the device owner.

Complaint is investigated by Measurement Canada and fines or other penalties are assessed, if necessary - 32
Complaint is investigated by Measurement Canada, the inspection results are provided to the complainant and the device owner - 61
The parties resolve the complaint on their own - 35

Question 10 - Alternative Service Delivery (ASD) Mechanisms

For device inspections, the majority of stakeholders have indicated they feel the alternative service delivery mechanism they would prefer for the following services normally provided by Measurement Canada is the accreditation program.

the accreditation program - 51
registration program - 18
another program - 1

For calibration of measurement standards (test weights) the majority of stakeholders have indicated they would prefer calibration by a “CLAS” laboratory recognized by The National Research Council of Canada (NRC), who are accredited by the Standards Council of Canada (SCC).

Calibration by a “CLAS” laboratory (recognized by The National Research Council, accredited by the Standards Council of Canada) - 43
Calibration by a laboratory which is recognized by the National Institute of Standards and Technology (USA) providing the lab meets Measurement Canada's standards - 16
Other (Measurement Canada) - 1
None - 1
Don't know - 28

For approval of device types (e.g. scale models), the majority of stakeholders have indicated they would prefer mutual recognition of approvals between Canada and USA (i.e. acceptance of Canada or US approvals).

Mutual recognition of approvals between Canada and USA (i.e. acceptance of Canada or US
approvals)- 34
Harmonization of approval requirements with International Organization for Legal Metrology (international standards) and acceptance of other countries' approvals providing they meet Measurement Canada's standards - 26
Other - 0
Don't know - 19

Question 11 - Compliance rate

The majority of stakeholders indicated they consider an acceptable level of compliance for devices used in this industry to be 100%.

100% - 52 (99%-2, 98% - 2, 97%-2, 95%-1)
90% - 37
80% - 6
70% - 3
60% - 1
50% - 0

The majority of stakeholders indicated they consider an acceptable level of compliance for commodities in this industry to be 100%.

100% - 44 (99% -2, 98% -2, 97% -1, 95% -1)
90% - 40
80% - 6
70% - 2
60% - 0
50% - 0
(+/- 3% - 2)

Question 12 - Performance Indicators

The majority of stakeholders indicated the primary type of performance indicator to be used to monitor this trade sector should be compliance rate (devices).

Compliance rate (devices) - 88
Compliance rate (commodities) - 39
Stakeholder consultations (TSRs) - 28
Stakeholder surveys - 17
# of Complaints received - 33
Don't know - 16

Question 13 - Trade Sector Review

Feedback shows the majority of stakeholders feel the circumstances that would lead to future Trade Sector Reviews in this industry should be when Measurement Canada's monitoring program indicates measurement problems.

Significant reduction in compliance rate - 57
Major changes in the industry that can have an impact on measurement accuracy - 53
Measurement Canada's monitoring program indicate measurement problems - 63
Stakeholders indicate that there is a lack of confidence in measurement accuracy - 42
None, no further trade sector reviews are needed - 3
Don't know - 9

Question 14 - Measurement Canada's Visibility

To increase its visibility, stakeholders indicated Measurement Canada should:

- have more visible inspection stickers
- inspect people who work in the forest business part time
- increase random checks
- advertise
- offer rewards for false measurement information
- perform more inspections
- contact and work with the industry and provincial scalers
- perform more in-field compliance audits on alternative service providers