CIRM ELECTRONIC DOCUMENT SERVICE TAG/MAAC Circular 03/01
Comité International Radio-Maritime
Black Prince Road Tel: +44 20 7587 1245 Fax: +44 20 7587 1436
LONDON SE1 7SJ http://www.cirm.org email@example.com 21 May 2001
To: All Members of CIRM Traffic Accounting Group
All Signatories to the CIRM MAA Code
Ladies and Gentlemen,
CIRM TA Group / MAA Code Joint Meeting 25 April 2001 - Minutes
1. The Minutes of a Joint Meeting of CIRM Traffic Accounting Group and MAA Code
Signatories, held at the JC Mandarin Hotel, Shanghai, on Wednesday 25 April 2001, are attached,
as TAG/MAAC 1/01-M.
2. Attention is drawn to the actions listed. Any comments or corrections should be addressed
to this office.
Captain C K D COBLEY
MINUTES OF A JOINT MEETING OF
CIRM TRAFFIC ACCOUNTING GROUP AND MAA CODE SIGNATORIES,
HELD AT THE JC MANDARIN HOTEL, SHANGHAI, ON WEDNESDAY 25 APRIL 2001
Chris Cobley Secretary-General CIRM
Brian Mullan Inmarsat Ltd C
Victor Hui Marine Radio Systems HX08 M
Guenter Krombach Debeg DP02 CM
Ottar Bjåstad NERA GB11 CM
Joseph Foo Jason Electronics C
Tito Lau SAAB Transpondertech C
Victor Vargas COMSAT Mobile Communications C
Steve Colburn Mackay Communications US02 CM
Jeff Schlacks Mackay Communications US02 CM
Weiguo Zhang Beijing MCN
Yumin Zhao Beijing MCN
Fengyuan Chen PR China Ship Design & Research Institute
Michael Rambaut Deputy Secretary-General
*C = CIRM Member
M = MAA Code Signatory
1.1 The Chairman welcomed members to Shanghai, and introduced the guest observers, Mr Zhang, Mr
Zhao and Mr Chen.
2. MINUTES OF LAST MEETING
2.1 The Minutes of the Joint Meeting of CIRM Traffic Accounting Group and MAA Code Signatories,
held at Inmarsat, London, on Wednesday 15 November 2000 (TAG/MAAC 2/00-M) were agreed.
3. MARITIME TRAFFIC ACCOUNTING: CURRENT ISSUES
Timescales for Billing and Payment
3.1 At the November meeting, a discussion had taken place on cooperation between AAs and LESOs
and, in particular, on timescales for billing and payment. It had been being proposed that AAs should take
action, within 30 days of receipt of an invoice, either to pay or to explain why payment could not be made or
might be delayed.
3.2 The Secretary-General said it was clear from that discussion that the main problems that existed
between AAs and LESOs concerned communication, and involved one or both parties not following good,
modern business practice. He felt that the MAA Code should be a suitable vehicle for establishing and
maintaining good practice. At present, however, the Code only required adherence to the minimum standard
of 90 days, as in ITU-T Recommendation D.90.
3.3 In order to promote better coordination with LESOs, he had suggested that it could be to the
advantage of all participants if the timescales in the Code were shortened and strengthened, to provide a
voluntary framework for a quicker and more responsive billing system, which could then be offered for
agreement by all AAs and LESOs who wished to advertise their commitment to a high quality service.
3.4 Signatories had therefore been requested to comment on this, and to indicate whether they would
support an initiative to reduce the timescale in the Code from 90 days to, say, 30 days from receipt of Invoice
along the lines discussed.
3.5 Two detailed replies had been received, as shown at Annex 1, and the general view amongst AAs
seemed to be that, with the very large numbers of accounts to be handled and the need to resolve a significant
number of errors to the satisfaction of the customer (i.e.: the shipowner), it would be quite impossible to
guarantee to be able to meet a 30 deadline, at present.
3.6 As a LESO, Mr Vargas (COMSAT) sympathised with Mr Hui’s comments, but felt that the vast
majority of charges could be dealt-with almost instantaneously. Many AAs did indeed settle most accounts
very quickly, but there were some chronically late payers. He agreed that there had to be a better way to
coordinate the changing of vessels from one AA to another.
3.7 The Secretary-General undertook to draw up an appropriate reply to the BSOG explaining why,
although AAs wished to be as helpful and cooperative as possible, and MAA Code Signatories would strive
to reduce delays, it would it would simply not be possible to guarantee shorter payment times at present.
Change of Ownership and AA
3.8 Mr Vargas emphasised that tracking changes of ownership and/or AA was one of the biggest
problems facing the industry at present. He asked whether AAs could report changes to a database, and
asked whether Inmarsat could help.
3.9 Mr Mullan said that Inmarsat would normally only be informed on change of flag, not on change of
AA, or even of change of ownership within a flag. He would be glad to enquire whether such information as
was held could be made available (possibly centrally, through CIRM), but cautioned that the database could
only be as accurate as the information provided to it.
3.10 In discussion, it was recognised that a better database would help: the problem was maintaining its
accuracy. The ITU MARS database was badly out-of-date. Inmarsat would look again at possibilities,
although this would have to be within the constraints of the issues of data protection and commercial
confidentiality. Meanwhile, the new PSA procedures should enable AAs who were PSAs to keep better
track of changes, and all members were encouraged to keep each other informed of changes, and to respond
more quickly to enquiries from other AAs and LESOs.
Action: Inmarsat; All members
Applicability of the MAA Code
3.11 The Secretary-General said that the original concept had been for the MAA Code to include all the
best AAs, and then to expand as a framework for inclusion of Service Providers and other entities in the
billing chain. However, there was now much change in the industry, as illustrated by the sad demise of EI06,
and by the expansion of major companies such as Telenor and Xantic. Procedures were changing, too, with
ISP and the new PSA scheme.
3.12 Whilst the MAA Code itself might not be the appropriate formal document for agreement between
AAs and LESOs, it had amply proved itself as a symbol of quality and trustworthiness and he assured all
members that he would do all he could to ensure that the MAAC and CIRM TA Group continued to provide
a valuable forum and framework for coordination and exchange of views and ideas between all parties
Coordination with ITU & Publicity
3.13 Listing MAA Code Signatories in the ITU List of Ship Stations still seemed unlikely, being seen by
some administrations as being too commercial. Mr Mullan said it might be worth considering an article in
Ocean Voice, which was now a Lloyds publication, but one in which Inmarsat still had some influence. He
would be willing to support such an article, and Inmarsat staff would be happy to help editing in journalistic
style. The Secretary-General welcomed this suggestion and undertook to prepare a draft article, which
would be circulated to members for their comments and inputs before submission via Inmarsat.
Action: Secretary-General; Inmarsat
4. LIAISON WITH INMARSAT
4.1 Mr Mullan presented the report at Annex 2, which had been prepared by Edna Kim, and added
further comments as follows.
Maritime Service Activation Registration Form (SARF)
4.2 The SARF was constantly evolving to improve the quality and timeliness of information being fed
into the database. One item not mentioned in the Annex was that it was planned to include the ship’s IMO
number, which was the only unique identifier that never changed.
4.3 As mentioned in the Annex, it was normal practice for Inmarsat to ask for an AA to be listed on
applications for GMDSS installations, and Inmarsat might well be able to insist on it for Inmarsat-C
activations. However, it could not be made mandatory without some form of legal or regulatory backing,
which could not yet be identified. This was still under discussion with IMSO and IMO, but had not yet been
resolved. In answer to a suggestion that ITU might provide the appropriate legislation, Mr Rambaut pointed-
out that this would involve getting it put on the agenda for the next WRC, which he did not feel would be a
very likely starter.
Status of PSAs
4.4 The current status was as shown in the Annex, with a total of 81 appointments expected by the end
Impact of PSA on AA Business
4.5 The issues were largely commercial, and it was difficult for Inmarsat to be able to take a position
without regulatory backing, as discussed above. It was pointed-out that ISPs were the agents of LESOs, not
Inmarsat. In discussion, it was thought that all or most MAA Code signatories had signed up as PSAs, so
this might no longer be an issue for CIRM.
4.6 The new procedures were felt to have resolved most of the issues on Barring. Mr Mullan said that
one new issue had arisen where equipment was leased to a shipowner who then defaulted on the lease
agreement. Some barring mechanism was needed for such situations, and this was being addressed by
Inmarsat and the LESOs
Coordination with LESOs.
4.7 Following on from Item 3 above, and noting that it had been some time since the AAs and LESOs
had met, it was agreed that a further joint meeting, under the joint sponsorship of CIRM and Inmarsat would
be very helpful. The Secretary-General was invited to arrange a joint meeting, in consultation with Inmarsat,
preferably at a time and place that would be convenient for a majority of BSOG members to attend.
5. FRAUD AND BAD DEBT
Credit Checking and Debt Recovery Services
5.1 Mr Rambaut reported that, following-on from the discussion at the Dublin meeting, the service being
offered by MRC had been found to be too expensive, even under a group scheme, and the CIRM Board had
given this low priority. In discussion, Mr Hui said that AAs naturally did their best to check
creditworthiness of new customers, but could not always get the cooperation of the previous AA.
5.2 It was agreed that blacklisting was inappropriate for CIRM, but seemed to be no problem for MRC.
This should be kept on the Agenda for discussion again when more AAs were present. Meanwhile, the
Secretariat was invited to investigate other options, including a further attempt to negotiate a more
favourable arrangement with MRC.
Confidential Review of Cases
5.3 A brief discussion was held off the record, as usual.
6. ANY OTHER BUSINESS
6.1 There was no other business.
7. ARRANGEMENTS FOR FUTURE MEETINGS
7.1 The following provisional arrangements were approved in principle, subject to confirmation by e-
mail consultation with members not present:
.1 Coordination meeting with LESOs: to be arranged, as discussed at 4.7, above.
.2 Joint CIRM TAG/MAAC in conjunction with the CIRM Autumn meetings at Inmarsat,
London, 21 November 2001.
.3 7th General Meeting of MAAC Signatories to be held in conjunction with the CIRM Spring
Meetings, in Italy, 24 April 2002.
8.1 The Chairman warmly thanked Beijing MCN for their participation and looked forward to
continuing cooperation in the future. There being no other business, he closed the meeting at 1515.
TIMESCALES FOR BILLING AND PAYMENT: INPUTS FROM MEMBERS
1. RS01 finds it difficult to support this initiative to reduce the time scale of payment from 90 to 30
days, as the usual problems, e.g. late invoicing by LESOs, late payments by customers, sale of vessels,
change of ship managers, etc make it almost impossible to settle all accounts within the 'idealistic' period of
30 days after receipt of invoices by RS01. In many cases, we find it difficult to settle all the invoices within
90 days, not to mention 30 days!
2. Having received the subject paper that towards the matter on timescale revision, I would like to note
that existing 90 days is a very reasonable period for verification and settlement of accounts and I assume at
least 80-90 % of AA as MAAC signatories do comply.
3. The cycle of billing and settlement in our experience goes like this :
4. The period of despatch of invoices from LESOs to reach AA which takes normally 10 days (in 1
case, we receive the package 2 months after despatch as the package was detained at the customs)
5. To check and verify and bill to end-users/shipowners, it will take approx 15 days with a client base
of say several hundred vessels/terminals. LESOs statements are not 100% correct and that AA also handles
billings from besides LESOs, there are still the old conventional radio traffic accounts, say, telex and
radiotelephone. This is a time and manpower consuming job as being a responsible AA, we are not simply
collecting and paying the charges. AA protects interest of both service providers as well as the users. So AA
receive statements from the many LESOs and coast station operators that it is absolutely impossible to
respond immediately to every service provider by 30 days.
6. Our very recent experience with LESO is that we receive statements on Inmarsat C traffic only
charges on call confirmation and months afterwards we still not received the details of actual call
transactions to match with the confirmation charges despite reminder to the LESO. Another major LES
presents statements with almost 30 percent of entry error on call confirmation charges of Inmarsat C that we
have to go line by line. There are also piracy Inmarsat A calls which are not detected until owners double
checked with vessels' masters.
7. 80 percent of rejections are not responded/confirmed by LESOs. Years afterwards we still receive
demand for payment for the mistakes by the LESOs because the billing and settlement are dealt by different
personal/department at the LESO office. One LESO claims for charges unpaid dated almost 5-10 years
before and the response is that the person acknowledged receipt of our rejections/clarification had been
transferred and such transfer happened 3 times in one single year.
8. In commercial practice, another 30 days has to be allowed for the shipowner/managers to verify and
9. LESO applying direct billing to shipowner/managers has the reason to demand a 30 days settlement
from owners/mangers. But to deal with professional accounting authorities operating internationally, the 90
days timescale is still fair.
10. Signatories of CIRM MAAC are generally independent and specialized accounting authorities
handling accounts for vessels of various nationality. Therefore in our point of view and stand, MAAC
signatories should not be accepting for any revision.
Inmarsat Report to CIRM Traffic Accounting Group Meeting, April 2001
Author: Edna Kim, Development Manager, Customer Services and Operations, Inmarsat
1. Maritime Service Activation Registration Form (SARF)
1.1 At the CIRM-TAG meeting in November 2000, the group raised an issue which is affecting
the provision by the ISP of the Inmarsat service in the maritime market, especially on the take-
up of mini-M terminals.
1.2 The Group referred to an entry on the Maritime Service Activation Registration Form
(SARF) whereby Inmarsat requires the End-User to select an Accounting Authority (AA) for
MESs that are going to be used for distress and safety. This is seen as an Inmarsat 'red-tape'.
Some regulators are using the argument that this is an Inmarsat requirement rather that a
1.3 The Group proposed that such decision be left at the discretion of the national regulatory
body, or modify the wording on the form to exclude non-GMDSS terminals.
1.4 Inmarsat reviewed the proposal to identify any legal, financial, operational, regulatory and
administrative issues. Unfortunately, consultation with external entities such as IMSO/IMO is
still outstanding. Inmarsat hopes to resolve the issue by end May 2001.
2. Status of the PSA Project:
2.1 As at 20 April 2001, Inmarsat has appointed 60 PSAs. It is expected that 21 more will
come on line by end May 2001.
2.2 Major maritime registries that were non-compliant PSAs have stopped activating Inmarsat
terminals. Countries such as Bahamas, Gibraltar, Denmark, Hongkong, Cayman Islands and
Netherlands accept all PSAs without any restrictions. However, there are also countries that
require the PSA to register first. These countries include Panama, Malta, Cyprus, Singapore,
Greece, St. Vincent and the Grenadines and Vanuatu. Inmarsat has provided the PSAs with
the requirements of the regulators as well copies of the required forms.
2.3 The regulatory body in Liberia and in Marshall Islands have requested for, and have been
approved, the extension to the cut-off date for non-compliant PSAs until end June 2001. This is
to enable them to finalise their procedures for authorising PSAs.
2.4 Extension has also been granted on a case-by-case basis to some countries that are still
on the process of changing their regulatory infrastructure. Information on the status of individual
non-compliant PSAs may be obtained from Inmarsat’s Customer Services and Operations Dept.
3. Impact of PSA on the AA business
3.1 Inmarsat have been informed of the concerns of some AAs that are not PSA. These AAs
are worried that PSAs are refusing to activate the customers unless the customers change their
billing entity to that of the PSA’s AA code.
3.2 Activation is a commercial issue and the PSAs, within the boundaries of national law, may
choose to activate only certain type of customers.
3.3 AAs that are not PSA may choose to establish an agreement with a PSA provided that the
AA has been authorised by its customers to select the PSA on their behalf.