First ITK training
We are very pleased that the training was so positively received and thank you that a total of over 50 people found time to talk to us about this extremely important topic.
As expected, we discussed a lot of interesting issues during a joint discussion at the end of the training. We are very pleased that the entire training ended in the spirit of the belief that the documentation of the "new" SMS is evolution current systems, a the key to success is right for her fit to entity.
We hope that the presented information will prove useful to you in the process of applying for the Single Safety Certificate. Of course, we encourage cooperation, including the construction, implementation and certification of SMS in accordance with the 4th Railway Package and we count on similar interest in trainings organized by ITK in the future.
All information about them will appear on our website and Facebook profile, so we invite you to visit them regularly.
Under the link below you will find a presentation that was made available during the training to download.
Selected questions asked during the OSS training:
1. Do we also apply for an Entity in Charge of Maintenance Certificate via OSS?
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ITK: No, we still submit such an application traditionally - on paper, by e-Puap, or using an electronic form (option preferred by UTK).
Details at the link: https://utk.gov.pl/pl/uslugi/ecm/uslugi/certyfikat-ecm/16667,Wydanie-nowego-certyfikatu-ECM.html
2. Can more than one proxy be indicated in the OSS application to act on behalf of the entity?
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ITK: As an Institute, we have not tested such a solution, but technically it seems possible. Especially that the OSS provides for the functionality of "sharing" the application for another user (account). Then, another person/persons logged into the system to whom the application was made available should have full access to it and the ability to enter data. This is a safe solution from the point of view of substitutability of persons acting on behalf of the entity, but it must be reflected in the representation authorizations presented in the OSS (remember also about stamp duty).
3. What is the issue of the security of our applications - if our proxy changes his job, will he still have access to our documentation in OSS?
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ITK: According to ERA recommendations, it is best to set up OSS accounts with work addresses (we log in with an email address). Then, when changing jobs, such a person loses access to the OSS account.
An alternative is to secure the contract with standard provisions on access to the company's data after the end of cooperation with it, and disable the access itself in cooperation with the OSS system administrator.
4. Should the documents submitted to the OSS be completed and signed in accordance with the templates and by authorized persons?
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ITK: To quote the guide of the President of UTK on the submission of applications by the OSS: "Documents placed in the OSS may be in the form of copies (e.g. scans, PDF files). If the requirements indicate that the document must be signed (e.g. security policy), it is necessary to include a document with a visible signature.”
5. If there is an SMS according to the third package, do we attach "clean" forms from the SMS according to the fourth package or "completed" - in accordance with the currently applicable SMS for issuing a Single Certificate?
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ITK: There is no definite answer here. In our opinion, the principle can be applied - if we submit an application for an entity that enters the market and has not used SMS before, the forms are obviously "clean". If we already have a certificate and we submit a "new" application only due to a change in regulations (old certificates cannot be extended), we see no problem in attaching completed forms (even, for example, a few lines) to emphasize that the system is already functioning and meets your tasks. It must be remembered that in the OSS system, apart from the system itself, we must also provide evidence of its operation.
6. What typical problems may arise at the stage of formal assessment of the application?
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ITK: Typical problems in the formal assessment of the application will not, in our opinion, differ from the assessment of "standard applications" - that is, as the statistics show, the most problems are with powers of attorney, signatures according to representation, stamp duty, copies of documents where originals are required, etc. A novelty may be an incorrectly addressed application to the Issuing Authority - in other words, if the applicant wanted to move around two countries (e.g. all of Poland and all of Germany), and would submit the application to the Polish Supreme Administrative Court (UTK), and not to EUAR._cc781905-5cde- 3194-bb3b-136bad5cf58d_
7. What are the initial fees for issuing a single certificate? Is it specified somewhere?
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ITK: Information on fees is explained on the UTK website. Quoting from the Office: “Currently, issuing a single security certificate is subject to a stamp duty of PLN 10. You must also pay a fee for submitting the power of attorney document in the amount of PLN 17. Both fees are payable to bank account Taxpayer Service Center of the capital city of Warsaw. Attention! The rules for calculating fees for issuing a single safety certificate will change after the completion of legislative work on the implementation of the 4th railway package.”
So, as we established during the training - currently there is a "promotion" - prices after the adoption of the relevant regulations will be definitely higher (we expect even several dozen thousand zlotys).
8. Are there any restrictions on the size of the attached files?
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ITKA: We had no problems with that - as far as we know the limit was set very high, at least at the stage of OSS development.
9. If it is necessary to change the certificate we have (valid until 2025), an application for a new uniform certificate should be submitted?
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ITK: Changing a certificate valid even until 2025 entails the need to obtain a Single Certificate according to the IV package and, in fact, submit an application to the OSS in the "application for issue" option. Please note that in the event of a change, an application for the expiry of previous certificates must be submitted in parallel. UTK, ensuring the continuity of the entity's operation, will expire the old certificate only when a new one is issued.
10. If I have A and B certificates as an entity, what option should I choose when applying for a single certificate?
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ITK: When switching from the A and B certificate to the Single certificate, we always submit the application as a "new" one - that is, an application "for a certificate", and not for its extension.
Sources for the documents we mentioned during the training:
ERA Advisory:
http://utk.gov.pl/download/1/60353/PrzewodzikSSCdlawnioskodawcow-versionPL.pdf
UTK Guide: