We have received a number of enquiries asking us to explain the changes between the aged standard AS3547:1997 Breath alcohol testing devices for personal use and the replacement standard AS3547:2019 Breath alcohol testing devices published 28th June 2019. The following is a very basic outline of each by way of comparison.
| OLD STANDARD | NEW STANDARD |
| AS3547:1997 Breath alcohol testing devices for personal use | AS3547:2019 Breath alcohol testing devices (‘for personal use’ is removed from the title) |
| Includes Type 1 devices – Single Use Devices | Has been omitted from 2019 Standard |
| Includes Type 2 devices – Hand Held Devices (Both Qualitative (passive) and Quantitative devices) | Includes Type 2 devices – Hand Held Devices - Quantitative Only (Qualitative (Passive) devices has been omitted from 2019 Standard) |
| Includes Type 3 devices – Fixed installation devices. E.g. Wall Mounted | Includes Type 3 devices – Fixed installation devices is included |
| Includes Type 4 devices – Vehicle and Machinery Interlock devices | Includes Type 4 devices – Vehicle and Machinery Interlock devices are included |
| 3.2.2 Calibration A Type 2 device shall have a minimum calibration period of 30 days and shall— (a) be capable of being recalibrated; (b) have a calibration setting which cannot be inadvertently adjusted; and (c) have an indication on the device of when recalibration is due. |
2.7 Calibration requirements The device shall maintain the performance requirements of Clause 2.4 The device shall be in accordance with the testing requirements of Clause 3, including the drift requirements at a minimum of 6 months. Points (a) to (c) remain the same. |
| Calibration process is according to the manufacturer’s instructions | Minimum calibration requirements introduced requiring post calibration test results at different levels to confirm accuracy and linearity over the critical range (0.000g/210L – 0.100g/210L) |
| Minimum requirements to be achieved for a device to be certified | Minimum requirements have been increased to demonstrate accuracy in differing environmental testing conditions, sample flow rates in addition to some metrological traceability requirements |
| Measurements are delivered in a BAC equivalent based on a breath to blood ratio of 2300:1 | A BAC equivalent is no longer used and is replaced by the alcohol in breath measurement |
| Measurements delivered in grams of alcohol in 100ml of blood based on the above breath to blood ratio (BAC) | Measurements delivered in grams of alcohol in 210L of breath (as utilised by Law Enforcement) |
There are no significant changes to CMM Technology™ clients as we currently only supply products with a minimum 6 monthly calibration period and under our existing NATA Accreditation (for calibrations), we utilise practices to confirm accuracy and linearity over the critical range. We have also established MU (Measurement Uncertainty) taking into consideration all of the factors that impact the recalibration process and this is applied to all calibrations performed by CMM Technology™.
In reference to the omission of the Passive testing devices from the 2019 Standard, this has been raised and is currently being addressed in proposals put forward to Standards Australia. It is expected that a revision of the standard will address passive test devices in parallel with single use devices and devices for personal use.
Questions & Answers
Q. When will the 1997 standard finally be superseded?
A. This is now in the hands of Standards Australia since there is only one laboratory in the world capable of meeting acceptable test requirements of AS3547:2019 and it is expected that the 1997 Standard will be extended to endure beyond December 28th 2020.
Q. The Preface detailed in AS3547:2019 states that the 1997 standard will remain current for 18 months from the time of publication of AS3547:2019 and that authorities may apply requirements at different times. What does this now mean?
A. The Preface in any standard is considered informative only and not normative and therefore this clause is now under review and it is expected that the18 month period will be extended – we are led to believe by many that it will be for a further 18 months which will in effect mean that the 1997 standard will persist until 28th June 2022.
Q. Will qualitative devices be the subject of certification under AS3547:2019?
A. A proposal has been presented to Standards Australia requesting that guidelines for single use devices, devices for personal use and passive devices be considered and included in AS3547:2019
Q. When will I need to change my devices to the AS3547:2019 Standard?
A. If you wish to upgrade your existing devices to new 2019 certified devices we can discuss these options with you as new approved devices become available so that we can supply a solution that will meet your needs and not massage your needs to meet a device’s capability.
Outcome
Clients can continue to use their existing certified devices and have them recalibrated by CMM Technology™ as we follow strict NATA audited procedures that meet the requirements specified in the 2019 standard.
We will keep you informed and update as new information comes to hand and if you wish to discuss options please contact:
Tony Calder on 08 6500 4100, 0458 838 111 or tony.calder@cmm.com.au