011 - Complaint
Investigate incorrect GMV results
The GMV test report contained issues marked as ‘Failed’, even though what they were expecting is physically impossible.
I was asking for an independent expert to examine the facts.
Filing Date: 21st July 2023
Reply Date: 18th August 2023
MMO Ref: C2298
Tier 1 Response:
REFUSED to investigate
I am writing to make an official complaint as per your official complaints procedure.
My contact details are:
James Glover, Managing Director of Maritime Systems.
Phone: 07966 169 432
The area of MMO I am complaining about is the I-VMS team.
This is separate complaint than the one previously filed and is about a specific item.
On the 13th March 2023 my company, Maritime Systems Ltd, received a letter citing the results of Independent I-VMS device testing on our device, MS-44, by an independent testing company GNV.
Of the three main points raised, one was that we fail testing referencing “Missing Status code messaging”.
In the GNV summary, it lists this as the only missing status flag.
STAT-001 – Confirmation of Status Flags
Raise ‘GSM Disconnect’ flag instead of ‘GSM.Disconnect.End’ flag
On inspection of the GNV report on this issue, no valid failures were found.
In the GNV report (attached), the relevant test is: Test STAT-001: Confirmation of Status Flags
GNV marked this test as a fail, yet it was not in the main testing methodology, but only added in the comments as an observation.
In the comments of this test it was noted that:
“All required status codes are present, but GSM disconnect flag is issued once the device restores GSM connection instead of when it loses it (GSM disconnect at 12:46 instead of 12:39 and at 13:51 instead of 13:14). No GSM disconnect.end flag is raised. “
This is not a relevant comment. The I-VMS Specification does not require a status flag to state that the GSM connection has been disconnected.
Based upon the above, the MS-44 was considered to have failed this test, but it is not correct. The MS-44 passed all required criteria.
In fact, it is physically impossible for a GSM tracking device to send a message that it has lost GSM connection, as it does not have any data connection to send the message on.
- what I want to happen to put things right?
I request a suitably experienced technical member of the MMO team, or an external advisor if there is no suitable internal MMO staff, inspects the GNV report, cross references it with the I-VMS specification and ascertains if the MS-44 device failed the status code requirements based on the evidence that was provided.
I request an explanation of why no one within the MMO was able to determine that the listed failure was not physically possible, or outside of the required specification.
I request evidence that the GNV report was appropriately reviewed by suitably technical members of staff.
As per your complaint procedures I expect a full response within 20 working days.
18 August 2023
Dear Mr Glover,
I write to you regarding your recent complaint submitted to Marine Management Organisation (MMO) on 21 July 2023.
MMO contracted GMV NSL, to complete independent testing on behalf of the MMO, following a compliant competitive tender process, noting that they have the required recognised technical expertise in the maritime technology field. MMO engaged with Maritime Systems Ltd, along with other Suppliers, prior to the independent testing so you were fully aware of the process involved, timelines and decision points. Your device did not pass independent testing which MMO explained in previous correspondence to you. MMO set out its reasons to revoke Type Approval status of the MS-44 device in in the letter of 18 May 2023, as such which we do not intend to repeat.
For the reasons we have set out above, I am unable to agree with your complaint and have therefore made the decision not to uphold this complaint.
Given the repeated correspondence to date, MMO have escalated your complaint directly to Tier 2. MMO believe this is the best way to manage your complaint therefore, you are within your statutory rights to escalate your complaint to the Parliamentary and Health Service Ombudsman.
Should you disagree with our response, and/or have any concerns about how your complaint has been handled, you are entitled to escalate your complaint externally to your Member of Parliament to refer complaints about administrative actions by the MMO to the Parliamentary Ombudsman (also known as the Parliamentary Commissioner for Administration).
Parliamentary and Health Service Ombudsman
Complaints helpline: 0345 015 4033 Fax: 020 7217 4000
Email: firstname.lastname@example.org Website: http://www.ombudsman.org.uk
Service Exception Lead
Marine Management Organisation