0100 - Complaint
Complaint to MMO about revocation of I-VMS approval
Abstract:
Complaint about the actions taken to revoke the approval of the MS-44 I-VMS device.
It wasn’t based on scientific fact, but instead on a personal view that a proposal to fix issues was not detailed enough.
The MMO highlighted 3 issues to be fixed, but there was only 1 that need to be resolved. 1 was fixed and 1 was not physically possible, and was a mistake by the testing company, GMV.
1: IP67 Status: Valid
A water leak position was identified, and we proposed a rectification using adhesive waterproof vinyl, which we had successfully trialled.
2: Blackout Performance: Fixed
The device was not sending notifications of weak GPS signals. We admitted our mistake in setting the value for “number of satellites visible” in our server code and had already fixed it.
3: Missing Status code: Invalid
The testing company misunderstood the requirements in the technical specification. They expected a message to be sent when the device lost mobile reception, which is not physically possible. We explained that data transmission occurs when the mobile phone signal is re-established.
Requested:
- A review of the testing process and a re-evaluation of my proposals by an independent person or team.
- Satlink should be re-approved as it is wrong that only 2 suppliers are available to the fishermen, especially as one may have conflict of interest issues as the software supplier for the UK VMS Hub, and the other has been responsible to fishermen receiving large fines from malfunctioning devices.
- Investigations into the Senior Management witch hunt against my company and their determination to have us removed from the approval regardless of our actions, should be undertaken.
- A comparison between the failures in the MS-44 device and the other suppliers devices should be made to ascertain if this is fair treatment.
Tier 1
Filing Date: 30th May 2023
Reply Date: 28th June 2023
MMO Ref: C2255
Tier 1 Response Abstract:
“The plan submitted by Maritime Systems did not provide sufficient evidence of how you intended to overcome the failures and the proposed fix plan submitted was not deemed adequate.”
There was no acknowledgment that 2 of the failures required no plan as they did not exist.
Tier 2 Complaint
Filing Date: 4th July 2023
Reply Date: 28th July 2023
MMO Ref: C2291
Dear MMO,
I am writing to make an official complaint as per your official complaints procedure.
The area of MMO I am complaining about is the I-VMS team and associated senior management.
We were an approved supplier of I-VMS devices and during 2022 and 2023 installed approximately 1000 devices as part of the I-VMS rollout.
In November 2022 the deadlines were extended whilst the MMO conducted independent testing on the approved devices. This affected the income of the business, but it was implied that this would only be for a few months, so the company had financial reserves to continue operating.
I regularly attempted to contact the I-VMS management team to get a progress update and to find out when we may be able increase sales again. This business had clerical staff and engineers that were doing very little work and this was absorbing set aside funds. Without knowledge of when they would be needed, we were not able to determine whether to make them redundant or keep them on.
On March 13th 2023, we received a letter stating we had failed independent testing and were not to continue selling devices as Type Approved.
The specific issues where:
- IP67 Status
- Blackout Performance
- Missing Status code messaging
We accepted the evidence on the IP67 status.
The independent testing evidence on the other 2 was flawed and we explained this to GMV and MMO on a subsequent technical call to review the evidence.
The MMO requested a proposal of how we would fix this these issues, to cover the following details:
- Corrective action you intend to take which addresses and fixes the specific technical issues that have been identified with your device during testing. This should include at a high level (so as not to impact supplier intellectual property rights) any changes you may need make to address the issues identified and meet type approval specification.
- Whether or not the technical fixes you’ve identified can be done by you directly or need support from a third party.
- Clear timescales for the time you consider it will take for the technical fixes to be implemented.
- How any proposed fixes to the technical issues identified during testing will address both devices that you intend to sell and install on vessels prior to installation and those devices that have already been sold and installed on vessels.
We promptly submitted a proposal answering the above points, including evidence of why some points raised could be fixed as the evidence from GMV was incomplete.
We also removed references that the MS-44 was “Type Approved by MMO” from all marketing.
During the next meeting on May 18th the MMO confirmed that the MS-44 had failed type approval based upon a lack of details in the proposal. This was summarised as a lack of evidence that we could produce Adhesive patches and distribute them effectively to our network of engineers, and a new element that was never raised before regarding the tamper status messages.
The Senior Management showed no intention of working with Maritime Systems and stated that any re-submission of a proposal would have to meet a very high standard to be considered. The manner of the statement was to imply that what ever we did, it would not be high enough.
One of the Senior Management, acting as deputy CEO, attempted to prevent me from requesting that the meeting was recorded.
Whilst I had until 10 am the next day to submit a response, after the meeting the MMO immediately released notice to industry of the revocation, thereby keeping my busy answering calls when I should have been drafting a response.
On the 19th May I submitted a detailed response answering all queries raised, but this was still rejected for trivial reasons.
This has affected me by making my business involvement and at serious risk of collapse. All staff have been made redundant and the servers we operate have been shut down. Fishermen who had purchased our system are no longer able to access their data.
We have missed out on foreign business export opportunities, and I am financially ruined with no income to support my family. My monthly debt payments far exceed my income and as I had taken business and personal loans to support the project, in belief that we were working with the MMO to make the project a success.
- what you want to happen to put things right?
I request an urgent review of the testing process and a re-evaluation of my proposals by an independent person or team.
Satlink should be re-approved as it is wrong that only 2 suppliers are available to the fishermen, especially as one may have conflict of interest issues as the software supplier for the UK VMS Hub, and the other has been responsible to fishermen receiving large fines from malfunctioning devices.
A 5 minute phone call to discuss the proposal could have saved public money from being unnecessarily spent.
Investigations into the Senior Management witch hunt against my company and their determination to have us removed from the approval regardless of our actions, should be undertaken.
A comparison between the failures in the MS-44 device and the other suppliers devices should be made to ascertain if this is fair treatment.
As per your complaint procedures I expect a full response within 20 working days.
I am writing to let you know what we have received your complaint, reference C2255 on 30/05/23.
As I understand it, you are unhappy about the MMO i-VMS team and associated management. If for any reason I have misunderstood this, please contact me at the earliest opportunity.
We take service seriously and therefore a colleague from the relevant service area will be assigned to investigate your concerns.
In line with our published complaints procedure, we aim to resolve all complaints within 20 working days of receipt but will also give you regular updates on progress by telephone if you have provided these details. As such, you should expect a full response to your concerns no later than 27/06/23.
I would like to thank you for contacting us and for your patience while we explore this matter in more detail.
Kind regards,
Laurie
Laurie Rodwell | Service Exception Lead | Marine Management Organisation (MMO)
Lancaster House | Hampshire Court | Newcastle upon Tyne | NE4 7YH
I am writing to you in response to your complaint, reference C2255. Please find attached our final response.
Should you disagree with our response, and/or have any concerns about how your complaint has been handled, you are entitled to tier 2 complaint review.
As per your published procedures, I am writing to raise my complaint to a tier 2.
This is referencing the reply to my initial complaint in the attached letter.
I do not consider that my complaint has been addressed fairly, and that subsequent actions from the MMO continue to lead me to the conclusion that this is a witch-hunt against myself or my company.
My requests for further information or explanation of the issues have been continuously declined.
Senior executives of the MMO have made public statements that are damaging to the reputation of myself and my company, without providing any proof.
What I request:
I request a review into original response and my other concerns from a senior lead in the MMO.
Financial compensation for the loss of earning these decisions have cost my company.
Reinstatement of Satlink as an I-VMS supplier.
I am writing to let you know what we have received your complaint, reference C2291 on 04 July 2023.
As I understand it, you are unhappy with our response to your original complaint and would like us to conduct further investigation. If for any reason I have misunderstood this, please contact me at the earliest opportunity.
We take service seriously and therefore a colleague from our Senior Leadership Team will be assigned to investigate your concerns. You will be contacted on the telephone number you have provided, to discuss your concerns in more detail, within 5 working days.
We aim to resolve all complaints within 20 working days of receipt but will also give you regular updates on progress by telephone if you have provided these details. As such, you should expect a full response to your concerns no later than 01 August 2023.
I would like to thank you for contacting us and for your patience while we explore this matter in more detail.
Kind regards,
Laurie
Laurie Rodwell | Service Exception Lead | Marine Management Organisation (MMO)
Lancaster House | Hampshire Court | Newcastle upon Tyne | NE4 7YH
Please see attached MMO response to:
- Your complaint C2291
- FOI request ATI3081
- FOI request ATI3082
We have included a copy of some of the data requested. I do hope you are assured from the above MMO addresses the points you have raised. We take the services we deliver seriously but have already used a significant amount of time responding to your continued correspondence, which is diverting resource away from other important duties we are required to undertake.
As a result, we consider these letters set out our final position and we will not respond to any further correspondence from you on these specific matters. You are entitled to engage with us on other aspects of our work and the services we deliver. However, this will be in line with our published service standards and previous engagement will be taken into account when considering how we approach this contact. We