Dear Sir/Madam,

Please see our feedback in reference to the Consultation Regulation Impact Statement – Swimming Pool Pumps from November 2016

Vipac believes that it is in the industry’s interest to have NATA accredited independent third party testing conducted for registration purposes for the following reasons:

-  There is a conflict of interest if a manufacturer conducts their own testing, without some appropriate form of accreditation relevant to the test

-  Test reports that are not NATA (or equivalent) endorsed could not be relied upon for consistency and accuracy, for example use of calibrated test equipment in line with industry practice

-  As demonstrated by the round-robin testing conducted to date, there are inconsistencies already in the test results, without introducing more testers to the equation.

-  Above everything else, the standard needs to be repeatable and reproducible, particularly in light of potential check testing.

Other comments:

-  A single test method should be selected to ensure pump efficiencies can be compared from one pump to the next

-  Vipac believes it is worth investigating what the effect of minor changes to the method of test and / or set-up can have on the star rating.

-  The method to test variable speed pumps is fundamentally different between the way single speed and multiple speed pumps are tested. We however need to ensure that the efficiencies and star rating performances can be fairly compared from one pump category to the next.

-  With all the research that has been conducted to date Australia should have its own AS or AS/NZS standard

Thanks and Kind Regards,

Taha Shaikh
Plumbing Group Supervisor

Vipac Engineers & Scientists Ltd
279 Normanby Road, Port Melbourne VIC 3207 Australia
Private Bag 16, Port Melbourne VIC 3207 Australia
t. +61 3 9647 9737 m. +61 438 792 339
e. w.www.vipac.com.au

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