Context EMSA – SafeSeaNet – Quality reporting HNS data The PROTECT-group is of the opinion (March 6, 2014) that in order to improve the quality of data in SafeSeaNet: 1.This data need to be validated near the source, before it is sent to SafeSeaNet; 2.Valid reference data need to be accessible to the reporting parties (Masters, Carriers, Agents), to support the reporting process; and 3.Harmonizing/standardizing the message formats throughout the reporting chain (Agent-LCA-NCA-SSN) could help to minimize erroneous data or data loss in SafeSeaNet.
Verification Any report is verified by the appropriate authority against valid reference data, before further assessment. When data from the report does not match this reference data, the report will or may be bounced. After bouncing, a revision of the report is required. But a revision does not necessarily improve the quality (accuracy) of the data. The revision could aim for satisfying the verification process only (referential integrity and data completeness).
Assessment When the report satisfied the verification process, the data is further assessed. The correctness of data is assumed, based on the obligation of the reporting party to provide accurate information. When the report have been assessed and further actions concerned authorized, the reported data is stored as a reference for operations.
Inspection When operations fail and the stored data is used in support of incidence response or calamity abatement, practice will prove the correctness of the data. When there is doubt about the correctness of data, the authority concerned may choose to inspect the situation or cargo concerned, from which the correctness of the data can be validated.
Accreditation & validation Ole’s suggestion: “Consider an accreditation process that will ensure that any third-party databases being used by industry are compliant with the Common Hazmat Reference Database (of EMSA), and that this point is included in the guidelines (on reporting Hazmat information)...” Cor’s suggestion: “Use a validated source for entering Dangerous Goods information by the reporting party… and the use of an unique reporting number could improve the quality of source data, and prove validation.”
Discussion Given the restriction that EMSA is reluctant to change the current SSN-messaging, how can EMSA help in the facilitation of existing reporting practices, such that it includes the suggestions above, improves the quality of the source data, and benefits both Authorities (incl. EMSA) and the reporting parties?
Disconnect between legislation and requirements (1)
Disconnect between legislation and requirements (2)
Obscure lines of responsibility & Accuracy of source data (1) Ultimate reporting responsibility lies with the master and/or his agents Sample source data provided to carrier agent: COPARN DG Segment: DGS+IMD+9+3166+++F-ES-E+*'FTX+AAD+++ENGINE, INTERNAL COMBUSTION’
Obscure lines of responsibility & Accuracy of source data (2) Which one is it, A, B (or D) – B and D have the same EmS F-E,S-E?
An even worse example if only a UN and Class provided! Obscure lines of responsibility & Accuracy of source data (3)
The answer may lie in the use of unique reference codes (or approved variant codes) Obscure lines of responsibility & Accuracy of source data (4) 3166|0101|ENGINE, FUEL CELL, FLAMMABLE GAS POWERED|Engine, fuel cell, gas powered. 3166|0201|ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED|Engine, fuel cell, liquid powered. 3166|0301|ENGINE, INTERNAL COMBUSTION|Engine, liquid powered. 3166|0302|ENGINE, INTERNAL COMBUSTION|Engine, gas powered. 3166|0401|VEHICLE, FLAMMABLE GAS POWERED|Vehicle, gas powered. 3166|0501|VEHICLE, FLAMMABLE LIQUID POWERED|Vehicle, liquid powered. 3166|0601|VEHICLE, FUEL CELL, FLAMMABLE GAS POWERED|Vehicle, fuel cell, gas powered. 3166|0701|VEHICLE, FUEL CELL, FLAMMABLE LIQUID POWERED|Vehicle, fuel cell, liquid powered. PS: The answer is B !
2010/65/EU makes extensive reference to SSN and incorporates the Waste Directive and ISPS in the Annex as well as 2002/59/EC. The NCAs (and others incl. EMSA) interprets this as the legal provenance to link all these directives directly to the SSN IFCD and the SSN XML reference guide, hence the changes applied to the PortPlus message; However, the options to improve the accuracy of source data were left out; o there is no provision for a unique reference code/variant code in the guide, hence the proposal for an accredited third-party database as well as an agreed standard for the URC/VC. Careful consideration should be given to its inclusion in the PortPlus message at this early stage – the code must be agreed and adopted first! PROTECT members should recognise the benefits of these options, to both Authorities (incl. EMSA) and the reporting parties. SSN XML Message Reference Guide v3
Extend the HAZMAT Guidelines, to support the reporting process, with the purpose to achieve accurate declarations; Introduce a unique reference code, to support the reporting practice in case an UN nr. alone is not sufficient or a UN nr. is not available, and include it in the CHRD after adoption by the Member States (MS); Liaise with the appropriate bodies – as IMO, UN and shipping industry representations - to assess a feasible route plan to have this unique reference code maintained and accepted internationally. Ask the NCA’s SSN in the MS to check data quality as provided by the reporting parties with the help of this unique reference codes; hereto: o Advice the MS to include the unique reference code in the national reporting process for SSN; Ask MS to maintain the PortPlus message as is, i.e. excluding the unique reference codes or variant codes in the notification sent to the central SSN system; Arrange with MS that this code is used in the national QA process for SSN; Make the CHRD – including the unique reference codes available for the SSN community, including the data providers who support the reporting process in the MS. Suggestion to EMSA