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Gen-26 Modifications to Approved Weighing and Measuring Devices and Electricity and Gas Meters

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Modifications to Approved Weighing and Measuring Devices and Electricity and Gas Meters, in PDF format, 52 KB

Table of Contents

1. Scope
2. Background
3. Reporting of Modifications to Approved Devices
4. Methods of Assessing Modified Devices
5. Methods for Conveying Modifications
6. Guidelines for Assessing Modifications
7. Additional Information

Date: 2003-05-29
Bulletin: Gen-26-E
Category: General

1. Scope

This bulletin applies to weighing and measuring devices, and to electricity and gas meters which have been approved for use in trade by Measurement Canada pursuant to the Weights and Measures Act, and the Electricity and Gas Inspection Act. The bulletin is to clarify Measurement Canada’s requirements for reporting modifications to devices that are used in trade applications. It does not apply to class type approvals for weighing devices.


2. Background

2.1
The Approval and Calibrations Services Laboratory of Measurement Canada, ACSL, is responsible for implementing the device type approval program which includes the evaluation of prototype patterns as well as pattern modifications which occur subsequent to device approval. For the purpose of this bulletin, weighing and measuring devices and electricity and gas meters will be referred to as devices.

2.2
When devices receive type approval under sections 14 and 15 of the Weights and Measures Regulations and sections 13 and 14 of the Electricity and Gas Inspection Regulations, the approval applies only to devices, of which the design, composition, construction and performance are, in every material respect, identical to that described in the material that was submitted, and that are typified by samples submitted by the approval applicant for evaluation.

2.3
A Notice of Approval provides notice that a specific device pattern conforms to the applicable regulatory requirements and is adequate for use in the approved applications. The applicant may then produce and/or sell devices of a specific type which meet this specific pattern, with the knowledge that they conform or are capable of conforming to the prescribed design, composition, construction and performance requirements.

2.4
The information included in the Notice of Approval provides a summary description of the physical characteristics, features and functions that assists in identifying approved devices that are presented for inspection. Modifications to a device which alter it from its original pattern approval can often result in delays to the inspection process. Maintaining accurate approval records is essential in providing continued recognition of device modifications and their descriptions.


3. Reporting of Modifications to Approved Devices

3.1
The approval applicant has an obligation to report all modifications to the Vice-President1, Engineering and Laboratories Directorate, to ensure that the originally approved pattern continues to comply with the requirements for device type approval and that the modifications can be conveyed accordingly. In order to adequately evaluate modifications and to determine the impact they will have on the device’s type approval, it is necessary for the applicant to provide ACSL with sufficient information. This shall include as a minimum, citing the existing approval that is affected, detailing the modifications made to the device and presenting data, analysis and conclusions concerning the consequences of the modifications. Based on both the previous approval evaluation of the original device type and on the modifications described in submitted documents and/or presented by physical samples, the method of assessing the modified device is determined.

Note 1: Director, as designated under the Weights and Measures and Electricity and Gas Inspection Act refers to the President of Measurement Canada. Authority to approve meters is delegated by the President to the Vice-President, Engineering and Laboratories Directorate.

3.2
Information submitted by an applicant during the device type approval process is considered to be proprietary information and can only be consulted at the request of the original applicant. When an approval modification request is submitted to Measurement Canada, it shall include the required information noted above and must originate from the approval applicant responsible for the device to which the modification applies, if it is to be considered by the Agency. The exception to this restriction is where the modification is a hardware modification which has been identified by the applicant in the Notice of Approval as detailed in subsection 6.3.


4. Methods of Assessing Modified Devices

4.1
The method for assessing if a post approval modification affects a device’s ability to measure accurately, alters a device’s metrological or technical characteristics or simply affects the superficial aspects of a device, will be based on one of the following three situations:

a) The modified device is still a replication of the approved type:

Devices produced by a particular manufacturer that are identical in design, construction and composition to the approved pattern but differ superficially in their colour for example or other immaterial and non-metrological aspects, can typically be considered covered under the original type approval notice. Usually, these types of modifications would only require an evaluation of the information submitted to determine the metrological impact of the modifications and/or an evaluation of how they have altered the physical identity or functionality of the device.

b) The modification is sufficient to require an amendment to the pattern approval for the device:

If the modification clearly affects one or more metrological characteristics of a device, then only a partial evaluation of the affected characteristics is necessary to determine compliance with applicable requirements1. However, a limited physical evaluation would be performed if the impact of a modification could not be determined by analyzing the information submitted. This would involve assessing all the relevant aspects suspected of affecting the metrological characteristics of the device.

c) The modification has altered the device to the point that it cannot be considered under the original notice of approval:

A full device type evaluation requires a device to be thoroughly evaluated against all applicable requirements for approval. This type of evaluation is typically for new device types or existing devices that have been modified to the extent that the device is now considered a new device.

a) modifications to the material composition of any part or component of an approved device where the compositional change is deemed to be inferior to the original composition and consequently could result in premature wear, increased measurement inaccuracies, or incompatibilities with other components of the device or the commodity that it is intended to measure.

b) modifications to the construction of an approved device which attenuate the device’s ability to resist exposure to the operating conditions as may normally be encountered during its intended service.

c) modifications to the original approved design of a device which include the reconfiguration, replacement and removal or addition of components and ancillary equipment which were not originally included in the approved design and can affect the measurement accuracy of the device over its intended life span, seal period, or other period prescribed by regulation or specification.

a) impact on the final quantity determination or price calculation, as applicable, or,

b) affect the validity of transactions.

a) configuration parameters that are either adjustable or selectable by the user that can affect the accuracy of measurement or resulting transaction or can significantly increase the potential for fraudulent use of a device.

b) computational functions where gross measured values or stored information are used in computations which result in net measured values or extended prices.

c) control functions where measured values and/or other system inputs and outputs are used to control measurement processes and data acquisition related to the measurement process.

d) measurement functions which could comprise any part of a measuring chain from the sensing of the commodity or service to be measured, up to and including the first legal and continuous display of the results of the measurement.