ARCHIVED—Livestock and Poultry Trade Sector Review — Recommendations Establishing Measurement Canada’s Level of Intervention in the Sector

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Table of Contents

1.0 Executive Summary

Over the past year, Measurement Canada’s sector review team has consulted with stakeholders in the livestock and poultry sector to determine how measurement accuracy will be achieved and the degree of involvement for Measurement Canada.

The stakeholders want Measurement Canada to remain involved in the sector and provide the services needed to maintain accuracy and confidence in the sector.

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

Approvals

  1. Measurement Canada should continue to require type approval for all weighing and measuring devices used for trade in this sector, with the exception of devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers.
  2. Weighing and measuring devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers should continue to be exempt from approval.
  3. Measurement Canada should harmonize its approval requirements with international standards such as the International Organization of Legal Metrology (OIML) recommendations.
  4. Approval testing should be conducted by organizations that meet a formal Measurement Canada alternative service delivery program, with the final approvals issued by Measurement Canada.
  5. Measurement Canada should expand the formal recognition program for other countries’ type approval processes of trade devices in this sector, with final device approval issued by Measurement Canada.
  6. Measurement Canada should expand mutual acceptance agreements with other countries for approval testing.

Initial Inspections

  1. Measurement Canada should continue to require mandatory initial inspections for all weighing and measuring devices used for trade in this sector with the exception of devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers.
  2. Weighing and measuring devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers should continue to be exempt from the requirement for initial inspection.
  3. Organizations other than Measurement Canada should be allowed to perform initial inspections provided they are authorized under the Measurement Canada accreditation or registration program requirements.

Periodic (Subsequent) Inspections

  1. Measurement Canada should require mandatory annual periodic inspections for all weighing and measuring devices used for trade in this sector, with the exception of devices used exclusively for formulating, testing and batching and for packaging standard sized packages or containers.
  2. Weighing and measuring devices used exclusively for formulating, testing and batching and for packaging standard sized packages or containers should be exempt from the requirement for annual periodic inspections.
  3. Periodic inspections should be performed by authorized service providers that meet the established requirements of either the Measurement Canada accreditation or registration program.
  4. A voluntary program for periodic inspections should be implemented in the sector until legislative changes can be made.

Physical Test Standards

  1. All physical test standards used by Measurement Canada inspectors and authorized service providers for inspections, should continue to be calibrated and certified according to the schedule in the Weights and Measures Regulations.
  2. Physical test standards used for inspections should be calibrated either by Measurement Canada or by a recognized laboratory that meets Measurement Canada’s alternative service delivery requirements.

Net Quantity (Commodity) Inspections

  1. Measurement Canada should continue to perform net quantity (commodity) inspections in the sector, on a random basis, until such time as an alternative service delivery mechanism can be put in place.

Complaints

  1. Measurement Canada should 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 should publicize its role as an investigator of trade measurement complaints in this sector.
  3. Measurement Canada’s legislation should allow for the full disclosure of complaint inspection information to the two parties to the transaction.
  4. Measurement Canada should use tickets or fines along with other forms of enforcement if the investigations and the inspections indicate that the requirements of the Weights and Measures Act are not met.

Monitoring The Sector

  1. Measurement Canada should monitor this sector by compiling compliance data on devices and commodities, by retaining complaint investigation results and by soliciting stakeholder feedback/input and disseminate this information in aggregate form on an annual basis.

Future Sector Reviews

  1. Future trade sector reviews should be conducted if, Measurement Canada’s monitoring program indicates measuring problems, there is a significant reduction in compliance rates, there are major changes in the industry that can have an impact on measurement accuracy or stakeholders indicate that there is a lack of confidence in measurement accuracy.

2.0 Introduction

This report contains the recommended level of involvement for Measurement Canada in the livestock and poultry sector. These recommendations are the result of extensive consultation with sector stakeholders to determine the programs and services needed to ensure the accurate measurement of goods and services at a reasonable cost and risk to the parties involved in the measurement transactions.

This report summarizes the views of the livestock and poultry sector stakeholders, established through consensus during the consultations, and provides Measurement Canada senior management with the supporting rationale and considerations behind each recommendation. The Livestock and Poultry Trade Sector Review team welcomes any comments, questions, or requests for clarifications on the contents of this report.

The document entitled A Discussion Paper on Establishing an Appropriate Level of Involvement for Measurement Canada in the Livestock and Poultry Sector, which was distributed to interested stakeholders in February 2009 and is located on Measurement Canada’s website, should be used as a reference for this report.

3.0 Scope

The Livestock and Poultry Trade Sector Review included the following products, devices and stakeholders associated with buying or selling, at the commercial level, based on measurement:

Products

  • live domestic and non-domestic livestock and poultry
  • cattle, hogs, sheep, goats
  • horses and other equines
  • bison, deer, elk, rabbits, wild boars, llamas etc.
  • poultry
  • ostriches, emus, pheasants etc.
  • meat and meat products
  • from abattoirs and meat packing plants
  • fats and oils
  • poultry products
  • from packing plants, eggs
  • non-meat products
  • PMU, antlers, hides etc.

Devices

  • platform scales, overhead rail scales, computing scales
  • in motion pre-pack scales and packaging scales
  • truck scales,
  • other trade measuring devices

The review did not pertain to devices that are not used in trade, nor with marketing, safety, environment or any other non trade measurement issues. This review did not pertain to retail trade of livestock and poultry products as this sector is under a separate trade sector review.

Stakeholders

  • livestock and poultry manufacturers
  • processors and packagers of livestock and poultry
  • wholesale and bulk dealers of livestock and poultry
  • bulk or wholesale consumers of livestock and poultry
  • any person or company who is paid or pays, based on measurement, for products or services in the livestock and poultry sector
  • associations representing groups of stakeholders
  • applicable federal and provincial government departments or organizations
  • measuring device (scales, meters, etc.) manufacturers and service and repair companies including organizations authorized to perform inspections on Measurement Canada’s behalf.

4.0 Methodology

Beginning in April 2008, the Livestock and Poultry Sector Review team contacted hundreds of industry stakeholders across the country to familiarize them with Measurement Canada’s programs and the trade sector review process.

The review team investigated trade measurement practices in the sector, and solicited views and comments from the stakeholders, regarding the Measurement Canada programs they would like to see in the industry, and how these programs could be best provided. The information obtained from these meetings was summarized in a discussion paper, which proposed the future role of Measurement Canada, and the necessary measurement programs within the sector.

The discussion paper was distributed to stakeholders with a request to provide a response and to indicate if they were interested in attending a consensus meeting to finalize the proposed recommendations. The majority of stakeholders who responded in writing or by phone indicated that they were in agreement with the draft recommendations and did not wish to attend a consensus meeting. As a result, all the scheduled consensus meetings were cancelled.

The recommendations based on the consultations and stakeholders’ comments, including dissenting opinions, are included in this report, and will be presented to Measurement Canada’s Senior Management Committee for review and acceptance, in May 2009.

Decision Making Criteria

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

  • the vulnerable parties 1 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 trade agreements

For the purposes of the review and this report, a consensus is a general agreement and does not necessarily imply unanimous agreement.

5.0 Recommendations

Stakeholders, almost unanimously, felt that Measurement Canada should remain involved in the livestock and poultry industry and maintain the programs that have been used to ensure measurement accuracy and fairness. They felt that Measurement Canada’s direct presence in the sector is critical in order to maintain stakeholders confidence.

5.1 Approvals

Before any device can be used in trade in Canada, a prototype must receive approval from the Measurement Canada Approval Services Laboratory located in Ottawa. The approval ensures that this device is capable of measuring accurately throughout its service lifetime.

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. Once it has been determined that the device type complies with all specified approval requirements, pattern or type approval is granted and a notice of approval is issued by the Approval Services Laboratory.

Currently, Weights and Measures Regulations exempts packaging devices used exclusively to measure standard sized packages or containers from the requirement for approval.

Measurement Canada currently conducts approval testing and issues type approvals, however under the United States / Canada Mutual Recognition Agreement, the examination and tests of certain fuel dispensers and scales performed by the United States are recognized by Measurement Canada.

In September 2006, Measurement Canada entered into a Mutual Acceptance Arrangement with member countries of the International Organization of Legal Metrology (OIML) for recognition of test results in the approval of non-automatic weighing devices and related modules. Mutual Acceptance Arrangements allow participating countries to utilize test reports from other countries in their own approval process.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.1.1 Measurement Canada should continue to require type approval for all weighing and measuring devices used for trade in this sector, with the exception of devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers.

5.1.2 Weighing and measuring devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers should continue to be exempt from approval.

5.1.3 Measurement Canada should harmonize its approval requirements with international standards such as the International Organization of Legal Metrology (OIML) recommendations.

5.1.4 Approval testing should be conducted by organizations that meet a formal Measurement Canada alternative service delivery program, with the final approvals issued by Measurement Canada.

5.1.5 Measurement Canada should expand the formal recognition program for other countries’ type approval processes of trade devices in this sector, with final device approval issued by Measurement Canada.

5.1.6 Measurement Canada should expand mutual acceptance agreements with other countries for approval testing.

Key Considerations/Rationale

Stakeholders agreed that device type approvals provide a benefit to the sector and should be maintained provided that Measurement Canada ensures that the Canadian standards are not lowered and that conditions unique to Canada, such as temperatures and geography, are accounted for in the approval requirements.

Stakeholders are free to use approved devices for formulating, testing and batching, and for packaging standard sized packages or containers, if they choose.

Harmonization with international standards and accepting other countries approval results would help to speed up the approval process, reduce duplication and would likely result in reduced costs.

Harmonizing approval requirements and accepting other countries’ approvals may reduce the amount of control that Measurement Canada has on type approval evaluations.

The Mutual Acceptance Arrangement program allows OIML member countries to rely on the facilities and competencies of other member countries for test results, thus reducing barriers to trade and enhancing competitiveness. The Mutual Acceptance Arrangement works to reduce duplication in testing and allows for a quicker turnaround on measuring device approvals.

Priority: High

Required Actions: (by Measurement Canada):

1 Harmonize approval requirements with international standards such as the International Organization of Legal Metrology.

Time line: Ongoing

2 Expand the formal recognition program for other countries’ type approval processes of trade devices in this sector, with final device approval issued by Measurement Canada.

Time line: Ongoing

3 Expand mutual acceptance agreements with other countries for approval testing.

Time line: Ongoing

4 Expand the formal Measurement Canada alternative service delivery program for private industry labs, with the final approvals issued by Measurement Canada.

Time line: Ongoing

5.2 Initial Inspections

An initial inspection is the first inspection or certification of each measuring device before it may be placed into trade service. This inspection is currently mandatory, and ensures that the device is approved, is installed correctly, and is measuring accurately within the limits of error (tolerances) set out in the Weights and Measures legislation. Currently, accredited organizations are authorized to perform inspections in the livestock and poultry sector, but registered organizations are not. Registered organizations would be granted this authority only if Measurement Canada’s Senior Management Committee accepts recommendation 5.2.3, shown below.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.2.1 Measurement Canada should continue to require mandatory initial inspections for all weighing and measuring devices used for trade in this sector with the exception of devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers.

5.2.2 Weighing and measuring devices used exclusively for formulating, testing and batching, and for packaging standard sized packages or containers should continue to be exempt from the requirement for initial inspection.

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

Key Considerations/Rationale

The vast majority of stakeholders felt that mandatory initial inspections are needed to ensure accuracy in the sector.

Stakeholders are free to use approved and initially inspected devices for formulating, testing and batching, and for packaging standard sized packages or containers, if they choose.

After comparing the accreditation and registration programs, stakeholders agreed that either one of the programs would be acceptable for performing initial inspections as long as there is no excessive cost to the industry.

Some stakeholders felt that because of the requirement for a quality system, the accreditation program would offer an additional level of confidence.

Measurement Canada’s position is that, because of the way packaging devices are used, inspection of a representative sample of the packaged products would have a more significant impact on the accuracy of the net contents of the packages or containers than inspection of the devices.

Priority: High

Required Actions: (by Measurement Canada)

1 Expand the registration program to include the livestock and poultry sector.

Time line: Immediate (within 6 months)

5.3 Periodic (Subsequent) Inspections

After the initial inspection, weighing and measuring devices are inspected throughout their service lifetime, either by Measurement Canada or an authorized service provider (accredited or registered company), to ensure they continue to measure accurately and are not used in a fraudulent manner.

Currently, there are no mandatory requirements for the in-service inspection of weighing and measuring devices in the Weights and Measures Act and Regulations.

Measurement Canada scheduled subsequent inspections are based on priorities and available resources, whereas the inspections by authorized service providers are based on requests by the device owner. Currently, registered companies are not authorized to perform inspections in the livestock and poultry sector. They would be granted this authority only if Measurement Canada’s Senior Management Committee accepts recommendation 5.3.3, shown below. It should be noted that other trade sector reviews have recommended making periodic subsequent inspections mandatory.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.3.1 Measurement Canada should require mandatory annual periodic inspections for all weighing and measuring devices used for trade in this sector, with the exception of devices used exclusively for formulating, testing and batching and for packaging standard sized packages or containers.

5.3.2 Weighing and measuring devices used exclusively for formulating, testing and batching and for packaging standard sized packages or containers should be exempt from the requirement for annual periodic inspections.

5.3.3 Periodic inspections should be performed by authorized service providers that meet the established requirements of either the Measurement Canada accreditation or registration program.

5.3.4 A voluntary program for periodic inspections should be implemented in the sector until legislative changes can be made.

Key Considerations/Rationale

Inspections involve more in depth testing than calibrations or checks, therefore they are more likely to detect measurement problems and incorrect device settings, installations or usage.

Measurement errors over a long period of time could be costly for one of the trading parties and could damage the reputation of companies as well as the sector.

Some stakeholders felt that mandatory annual inspections would be costly especially for smaller companies and companies in remote locations.

Some stakeholders felt that it would be better base the frequency of the periodic inspections on the volume of product measured by the devices. They felt that companies that measure a smaller volume products should not have to inspect their devices as often. This would help to minimize the cost of periodic inspections for smaller companies.

After comparing the accreditation and registration programs, stakeholders agreed that either one of the programs would be acceptable for performing inspections.

Having the device inspections done by authorized service providers will free up Measurement Canada’s resources to focus inspections on problem areas and to monitor the overall performance of the livestock and poultry sector.

Stakeholders generally supported the use of a voluntary periodic certification program until the Weights and Measures Act can be changed to make periodic inspections mandatory. They felt that most stakeholders already inspected or calibrated their devices at least once per year and would likely participate in the voluntary program.

Measurement Canada would need to communicate with stakeholders and explain the benefits of participating in the voluntary program.

Priority: High

Required Actions: (by Measurement Canada)

1 Expand the registration program to include the livestock and poultry sector.

Time line: Immediate (within 6 months)

2 Expand the Voluntary Periodic Certification Program to include the livestock and poultry sector.

Time line: Immediate (within 6 months)

3 Develop a communications plan that will inform stakeholders of the implementation of the Voluntary Periodic Certification Program and explain the benefits of the program.

Time line: Immediate (within 6 months)

4 Change the Weights and Measures Act to institute mandatory periodic inspections.

Time line: Medium term (2 to 3 years)

5 Ensure the stakeholders are kept informed, especially when mandatory periodic inspections are put in place.

Time line: Medium term (2 to 3 years)

5.4 Physical Test Standards

Test standards used for inspections are certified by Measurement Canada according to the schedule in the Weights and Measures Regulations. All the test standards are calibrated or referenced to a national physical standard which is held by the National Research Council of Canada (NRC). Certified test standards are therefore traceable to the international 1 kg standard.

Measurement Canada has established and implemented an alternative service delivery program, where physical test standards used for inspections, may be certified by Measurement Canada, based on test results from recognized calibration laboratories.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.4.1 All physical test standards used by Measurement Canada inspectors and authorized service providers for inspections, should continue to be calibrated and certified according to the schedule in the Weights and Measures Regulations.

5.4.2 Physical test standards used for inspections should be calibrated either by Measurement Canada or by a recognized laboratory that meets Measurement Canada’s alternative service delivery requirements.

Key Considerations/Rationale

All stakeholders agreed that test standards used by Measurement Canada inspectors and alternative service providers (accredited and registered companies) need to be certified in order to maintain traceability to international standards.

Stakeholders felt that, as long as the test standards have the same level of traceability as those calibrated by Measurement Canada, they would accept calibrations conducted by other qualified laboratories. Certifications would continue to be issued by Measurement Canada.

Most stakeholders accept an alternative service delivery program that allows other organizations to calibrate test standards, as long as there are sufficient controls to ensure the standards are correctly calibrated and traceable to the international standard.

Stakeholders who use certified test standards like the idea of having a viable alternative besides Measurement Canada for calibration of test standards, as long as the service is not too costly and reduces the turn around time.

Priority: High

Required Actions: (by Measurement Canada)

1 Expand the alternative service delivery program allowing the use of test results from recognized laboratories for the calibration of test standards. This program has already been launched and is expected to continue to expand and evolve.

Time line: Ongoing

5.5 Net Quantity (Commodity) Inspections

The net quantity of livestock and poultry products which are sold in bulk or packaged for wholesale use, fall under the Weights and Measures Act. These products are usually randomly tested for net quantity by Measurement Canada inspectors based on priorities and available resources or in response to complaints.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.5.1 Measurement Canada should continue to perform net quantity (commodity) inspections in the sector, on a random basis, until such time as an alternative service delivery mechanism can be put in place.

Key Considerations/Rationale

Stakeholders agreed that the inspection of the net quantity of commodities was a program that needs to be maintained. They felt that because the compliance rates were relatively high, random net quantity inspections would be sufficient.

Some stakeholders suggested that Measurement Canada should use compliance rates as well as whether or not companies have quality systems to determine the frequency of net quantity inspections.

Priority: Low

Required Actions: (by Measurement Canada)

1 Maintain the net quantity inspection program.

Time line: Ongoing

5.6 Complaints

Measurement complaints received by Measurement Canada are usually investigated by Measurement Canada inspectors and if necessary, devices or commodities are inspected. The complainant is then informed as to whether the device, product or service meets the requirements of the Weights and Measures Act. If an inspection indicates that the device or the commodity does not meet legislated requirements, then normal enforcement actions such as rejections, seizures, prosecutions, etc., are taken.

Measurement Canada does not have the authority to compel the device owner or the complainant to provide compensation, even if the complaint is justified.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.6.1 Measurement Canada should 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.

5.6.2 Measurement Canada should publicize its role as an investigator of trade measurement complaints in this sector.

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

5.6.4 Measurement Canada should use tickets or fines along with other forms of enforcement if the investigations and the inspections indicate that the requirements of the Weights and Measures Act are not met.

Key Considerations/Rationale

The vast majority of stakeholders have indicated that any measurement complaints should be resolved between the parties involved.

Stakeholders agreed that the complaint process was needed for stakeholders in the sector, but added that Measurement Canada should promote themselves as being an option for stakeholders to lodge complaints.

Measurement Canada has received very few measurement complaints from the Livestock and poultry sector. There is some question about whether the very small number of complaints received was a result of satisfaction with measurement, or of stakeholders being unaware that this was an available option.

Providing the results of the investigations and inspections to the complainants would help them to resolve the complaint, and seek compensation if warranted.

Fines or ticketing would provide an intermediate enforcement step that would give Measurement Canada the flexibility to penalize certain infractions before resorting to the more severe penalties such as prosecutions.

Priority: Medium

Required Actions: (by Measurement Canada)

1 Develop a policy clearly outlining what information from complaint inspections/investigations could be provided to a complainant.

Time line: Short term (1 to 2 years)

2 Develop communications with stakeholders in the sector in an effort to ensure they are aware that they can lodge a complaint with Measurement Canada, if they are not satisfied with measurement accuracy.

Time line: Short term (1 to 2 years)

3 Investigate the possibility of obtaining an exemption from the Access to Information and Privacy Act for release of the results of complaint information to the complainant.

Time line: Medium term (2 to 3 years)

4 Institute fines and tickets as part of Measurement Canada’s enforcement policy.

Time line: Medium term (2 to 3 years)

5.7 Monitoring The Sector

Measurement Canada monitors the marketplace usually through data collected from inspections conducted by Measurement Canada inspectors and by authorized service providers and from Measurement Canada investigations. The majority of this data is in the form of compliance tables for different device types and for different commodities. Measurement Canada uses this data to identify problem areas and to help prioritize its inspection programs. As the use of authorized service providers for scheduled inspections increases, Measurement Canada is focussing more of its resources on monitoring the marketplace for compliance to its legislation.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.7.1 Measurement Canada should monitor this sector by compiling compliance data on devices and commodities, by retaining complaint investigation results and by soliciting stakeholder feedback/input and disseminate this information in aggregate form on an annual basis.

Key Considerations/Rationale

Stakeholders agreed that the criteria proposed would be acceptable to monitor the sector.

Stakeholders felt that Measurement Canada should conduct more random inspections as part of the monitoring program and maintain a direct presence in the marketplace.

Priority: Medium

Required Actions: (by Measurement Canada)

1 Develop and implement a monitoring program for the sector.

Time line: Short term (1 to 2 years)

2 Develop a user friendly format with explanations, for reporting the performance of the sector and determine distribution points, i.e. Measurement Canada website, industry newsletters etc.

Time line: Medium term (2 to 3 years)

5.8 Future Sector Reviews

Since 2000, Measurement Canada has completed reviews in 12 out of 39 identified sectors. The accepted recommendations have already been implemented or are in the process of being implemented. To date, there have been no subsequent reviews.

Recommendations

A consensus of stakeholders and the Livestock and Poultry Trade Sector Review team recommend that:

5.8.1. Future trade sector reviews should be conducted if, Measurement Canada’s monitoring program indicates measuring problems, there is a significant reduction in compliance rates, there are major changes in the industry that can have an impact on measurement accuracy or stakeholders indicate that there is a lack of confidence in measurement accuracy.

Key Considerations/Rationale

Stakeholders appreciated the opportunity to find out about different Measurement Canada programs and to provide input on the level of involvement for Measurement Canada in the sector.

Sector reviews require a significant amount of resources, and holding a review for the sake of having a review could be costly without significant benefits.

Future reviews do not have to be as in depth as the first one.

Priority: High

Required Actions: (by Measurement Canada)

1 Develop measurable criteria for holding future sector reviews.

Time line: Medium term (2 to 3 years)

1Vulnerable Party - the purchaser or seller of a product and who does not own or control the measurement equipment used in the transaction. The degree of vulnerability depend upon the capacity and ability of the vulnerable party to detect measurement errors, re-measure the product and have corrective measures taken where appropriate.