GEN-26 — Modifications to Approved Weighing & Measuring Devices and Electricity & Gas Meters

GEN-26—Modifications to Approved Weighing & Measuring Devices and Electricity & Gas Meters (PDF, 49 KB, 4 pages)

Category: General
Bulletin: GEN-26 (rev. 1)
Document(s): W&M Act, sections 8 and 29
Issue Date: 2008-09-01
Effective Date: 2008-10-01
Supersedes: GEN-26

Table of Contents

1.0 Purpose

The purpose of this 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.

2.0 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, or the Electricity and Gas Inspection Act. For the purpose of this bulletin, weighing and measuring devices and electricity and gas meters will be referred to as devices.

3.0 Background

A Notice of Approval (NOA) issued under sections 14 and 15 of the Weights and Measures Regulations and sections 13 and 14 of the Electricity and Gas Inspection Regulations applies to any device that is, in every material respect, identical to the device originally submitted for approval evaluation. During the lifespan of a design, the manufacturer may decide to make design modifications. Changes may be superficial, or they may affect the metrological or technical characteristics of the device. Some changes may affect the approval status of the new device design.

4.0 Reporting Modifications to Approved Devices

4.1 Modifications to a device, which alter the originally approved design, must be reported to the Measurement Canada Engineering and Laboratory Services Directorate (ELSD). The ELSD will then review the proposed changes and advise the manufacturer/approval applicant if the modifications are substantial enough to warrant a re-evaluation of the device and/or a modification to the original Notice of Approval.

4.2 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 6.2.

5.0 Assessing Modifications to Approved Devices

When modifying an approved device, the manufacturer should be aware that the modifications may not be covered by the current NOA. In these cases an amendment to the existing approval, or a new approval may be required. All modifications must be reported to Measurement Canada Approval and Calibration Services Laboratory (ACSL) to ensure that the approval issues are addressed. The following guidelines shall apply:

No formal notification is required when a modification to an approved design clearly represents a metrologically insignificant, superficial change (e.g., colour).

5.1 Modifications that affect more pronounced features related to the design, composition and construction of a device but do not impact on the metrological characteristics (e.g., case style, layout, etc.), shall be reported in order to continue to convey an accurate description of the approved device. These modifications are considered to be minor and the modified device is still covered by the original NOA. ACSL may choose to issue a Modification Acceptance Letter (MAL) to convey information about a device's modifications which are deemed metrologically insignificant but which have altered the device's design, composition or construction characteristics. These types of modifications can often be assessed by a review of the documentation required under section above.

5.2 When a modification affects the metrological aspects of the device, or when the modification has significantly altered the design of the device, a report is required and a revision to the Notice of Approval may be required. If the modification or modifications are clearly identifiable, then only a partial evaluation of the affected characteristics may be necessary to determine compliance with applicable requirements Footnote 1

5.3 When a modification has significantly altered an approved device, it may no longer be considered as approved under the original NOA. In this case, the device will be considered as a new design and a complete new approval evaluation will be required. A new NOA would be issued for the device upon successful evaluation by ACSL.

5.4 A Notice of CLASS Approval (NOCA) will identify the CLASS Approval holder. Authority to manufacture and install devices using the NOCA extends only to the CLASS Approval holder. Use of the CLASS Approval, including significant modifications to existing CLASS approved weighing devices, by persons other than the CLASS Approval holder must be approved in writing, by the CLASS approval holder.

6.0 Guidelines for Assessing Modifications

With the ever increasing variety and complexity of devices the approval process continues to increase in complexity. As a result, the distinction between what constitutes a significant and insignificant metrological modification is becoming less and less apparent.

While it would be a formidable undertaking to describe and list all the possible modifications to a device, the following general examples shall be used to assist in determining what constitutes a significant metrological modification.

6.1 Hardware Modifications

These types of significant metrological modifications include changes to the composition, construction and design which may affect the performance of a device. Modifications of this nature can increase the potential for fraudulent use of a device or compromise a device's ability to measure accurately within its expected life cycle, seal period or within periods of time otherwise prescribed by regulations and specifications. Examples of such modifications may include the following:

  1. modifications to the material composition of any part or component of an approved device where the compositional change is deemed to be substantially different than 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.
  2. 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.
  3. 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.

6.2 Hardware Modifications identified in the Notice of Approval

Other forms of hardware modifications may be permitted without having to comply with the reporting structure stipulated above. To recognize these type of non-metrological modifications, the approval applicant shall identify them during the approval process. The Notice of Approval will identify these permitted modifications and there will be no need for further reporting.

6.3 Software Modifications

Software modifications which affect metrological functions of the device. A metrological function is defined as a function of a device which is necessary for the measurement process, including the sensing of the measured quantity, the transmission, processing, storage and correction or adjustment of measurement signals or values which can:

  1. impact on the final quantity determination or price calculation, as applicable; or,
  2. affect the validity of transactions

Some examples of significant metrological software modifications include:

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

1.1.2 Computational functions where gross measured values or stored information are used in computations which result in net measured values or extended prices.

1.1.3 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.

1.1.4 Measurement functions which could comprise any part of a measuring sequence, 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.

7.0 Revisions

The purpose of this revision is to simplify the requirements regarding Modifications to Approved Weighing & Measuring Devices and Electricity & Gas Meters. (PBRI2008).

8.0 Additional Information

For additional information regarding this bulletin, please contact the undersigned.

Gilles P. Vinet
Vice-President
Program Development

Footnote 1 "Applicable requirements" refers to requirements that are currently in force. (Return to footnote 1 reference)