September 16, 2020
The Ministry of Internal Affairs of Ukraine, in accordance with the Procedure for Public Consultations on the Formation and Implementation of State Policy, approved by the Resolution of the Cabinet of Ministers of Ukraine dated November 03, 2010 No. 996, conducted electronic consultations with the public on the draft order of the Cabinet of Ministers of Ukraine “On Approval of the Concept creation of a system of emergency assistance to the population at the single telephone number 112”, which was published on August 12, 2020 on the official website of the Ministry of Internal Affairs: here.
Information on proposals received during electronic public consultations and on the results of their consideration is given in the table.
| No. of sales/n | Offer Information | Author of the proposal | Offer Consideration Information |
| ! 1 |
When developing and implementing the 112 system, it is proposed to take into account the possibility of using an emergency call system for people with hearing impairment, which should have a choice of channels for calling emergency services (video communication, SMS call, mobile application, computer, fax). |
Sign language interpreter of the NGO “Kreavita” Uliana Frankivska (ul. Volynska, 18, m. Kharkiv, 61009) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, in particular, the determination of the procedure for the organization of receiving notifications of emergency situations coming to the 112 system from persons with disabled people, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. Today, the Ministry of Internal Affairs is considering various options for design solutions to ensure the possibility of calling emergency services by persons with disabilities, including those with hearing impairments. For the optimal choice of such a design solution, it is necessary, first of all, to conduct a study of the functionality of a typical software and hardware complex of the automated workplace of the Operational Dispatch Service of the 112 system regarding the maintenance of emergency notifications and appeals in connection with the need for emergency assistance by persons with disabilities, including persons with hearing impairments with subsequent analysis of such proven solutions and technical capabilities. |
| ! 2 |
It is suggested to pay attention to the mobile application “911help” of the NGO “Ukrainian Systems and Blockchain Solutions”, which provides a call without audio communication of emergency services. |
Sign language interpreter of the NGO “Kreavita” Uliana Frankivska (ul. Volynska, 18, m. Kharkiv, 61009) First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (str. Velyka Vasylkivska, 74, m. Kyiv, 03150) Chairman of the Board of the NGO “United Hearts Fund” Natalia Pastushenko (Sonychnyi, 27/96, m. Kryvyi Rih, 50056) Head of the Vinnytsia Regional Branch of the All-Ukrainian NGO “Ukrainian Union of Persons with Disabilities — Usi” Olesya Samoilenko (str. O. Gonchara, 14, m. Vinnytsia, 21008) | Not taken into account. The draft act was developed in order to define approaches to the creation, implementation and operation of the 112 system. Thus, the draft act is only conceptual in nature and does not define the specific organizations, technical means or software products required for the functioning of the 112 system. At the same time, we note that the proposal of the public union “Ukrainian Systems and Blockchain Solutions” on the national integration of the software application “911help” into the 112 system of the Ministry of Internal Affairs was taken into account. |
| ! 3 |
It is proposed to pay attention to the mobile application “112.in.ua” of the NGO “Ukrainian Systems and Blockchain Solutions”, which provides a call without audio communication of emergency services. |
Head of the NGO “Center for Sustainable Development Initiatives” Natalia Bukina (ul. Akademika Kurchatova, building 8-b, sq. 111, m. Kyiv, 02156) |
Not taken into account. The draft act was developed in order to define approaches to the creation, implementation and operation of the 112 system. Thus, the draft act is only conceptual in nature and does not define the specific organizations, technical means or software products required for the functioning of the 112 system. At the same time, we note that the proposal of the public union “Ukrainian Systems and Blockchain Solutions” on the national integration of the software application “112.in.ua” into the 112 system of the Ministry of Internal Affairs was taken into account. |
| ! 4 |
It is noted that the draft act does not apply to such a social group of the population as people with disabilities and contradicts Art. 9 of the UN Convention on the Rights of Persons with Disabilities and paragraph 1.1 of the Decree of the President of Ukraine of 03.12.2019 No. 975/2019 “On Improving the Effectiveness of Measures in the Field of the Rights of Persons with Disabilities” with regard to the creation of conditions for emergency calls by persons with disabilities, including persons with speech and/or hearing impairment, emergency calls. | Chairman of the Board of the NGO “United Hearts Fund” Natalia Pastushenko (Sunny, 27/96, m. Kryvyi Rih, 50056) Head of the Vinnytsia Regional Branch of the All-Ukrainian NGO “Ukrainian Union of Persons with Disabilities — Usi” Olesya Samoilenko (str. O. Gonchara, 14, m. Vinnytsia, 21008) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 5 |
It is noted that the 112 system does not automatically provide access to the emergency assistance system for persons with hearing impairment. In this regard, it is proposed to change the name of the draft act to “On Approval of the Concept of Creating a System of Emergency Assistance to a Healthy Population by a Single Telephone Number 112”. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 6 |
It is noted that the draft act does not provide for accessibility for persons with hearing impairment and does not take into account the possibility of calling for emergency help, for example, by a completely deaf person. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 7 |
It is noted that the eighth paragraph of the section “Problems that need to be solved” of the draft act is incomplete and incomplete due to the presence of discrimination against persons with hearing impairment. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The term “population of Ukraine” is a set of all individuals residing at a particular moment in the territory of Ukraine and subject to its jurisdiction. Thus, the concept of “population of Ukraine” includes all people, including people with disabilities. In this regard, it is inappropriate to single out individual categories of the population in the draft act. At the same time, the section “Ways and methods of solving the problem” of the draft act states that the creation of the organizational and institutional structure of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving emergency notifications from persons arriving to the 112 system with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 8 |
It is noted that the draft act does not provide for the possibility of including domestic software developments and information and communication solutions in the 112 system components that will provide access to the system for 112 persons with hearing impairment. | First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) | Not taken into account. The draft act was developed in order to define approaches to the creation, implementation and operation of the 112 system. Thus, the draft act is only conceptual in nature and does not define the specific organizations, technical means or software products required for the functioning of the 112 system. |
| ! 9 |
It is proposed that the second paragraph of the section “Problems that need to be solved” be stated in the following version: “A key indicator of the effectiveness of the actions of emergency response services is the time of their prompt response and accessibility for persons with hearing impairment. Its reduction directly affects the scale of the consequences of the emergency (reducing the number of dead and injured in emergency situations, as well as reducing material damage from them). And accessibility for people with hearing impairment affects the rate of inclusion of the entire population in the emergency care system.” |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The term “population of Ukraine” is a set of all individuals residing at a particular moment in the territory of Ukraine and subject to its jurisdiction. Thus, the concept of “population of Ukraine” includes all people, including people with disabilities. In this regard, it is inappropriate to single out individual categories of the population in the draft act. At the same time, the section “Ways and methods of solving the problem” of the draft act states that the creation of the organizational and institutional structure of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving emergency notifications from persons arriving to the 112 system with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 10 |
In order to eliminate discrimination against persons with hearing impairment, it is proposed to provide in the draft act a link that, through an electronic communication system, including not only a telephone call, but also video communication and publicly available software, will guarantee the availability of 112 persons with hearing impairment to the system. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. Today, the Ministry of Internal Affairs is considering various options for design solutions to ensure the possibility of calling emergency services by persons with disabilities, including those with hearing impairments. For the optimal choice of such a design solution, it is necessary, first of all, to conduct a study of the functionality of a typical software and hardware complex of the automated workplace of the Operational Dispatch Service of the 112 system regarding the maintenance of emergency notifications and appeals in connection with the need for emergency assistance by persons with disabilities, including persons with hearing impairments with subsequent analysis of such proven solutions and technical capabilities. |
| ! 11 |
It is proposed to provide in the Law of Ukraine “On the system of emergency assistance to the population at the single telephone number 112” and other relevant legal acts the availability of the 112 system for the entire population, especially for persons with hearing impairment. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The draft order of the Cabinet of Ministers of Ukraine “On Approval of the Concept of Establishing a System of Emergency Assistance to the Population at the Single Telephone Number 112” is an act of the Cabinet of Ministers of Ukraine on organizational and administrative issues and is not a normative legal act. Amendments to the Law of Ukraine “On the system of emergency assistance to the population at the single telephone number 112” is carried out in accordance with the legislative procedure established by the Regulations of the Verkhovna Rada of Ukraine, which was approved by the Law of Ukraine of February 10, 2010 No. 1861-VI. |
| ! 12 |
It is proposed in the draft act to note that when developing and improving legislation in the field of emergency assistance to the population, it is necessary to take into account the provisions of the UN Convention on the Rights of Persons with Disabilities. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The Convention on the Rights of Persons with Disabilities was ratified by the Law of Ukraine No. 1767-VI of 16.12.2009 and is an international treaty of the United Nations on human rights aimed at protecting the rights and dignity of persons with disabilities. In accordance with the Regulation on the Ministry of Internal Affairs of Ukraine, approved by the Resolution of the Cabinet of Ministers of Ukraine dated October 28, 2015. No. 878, the Ministry of Internal Affairs in its activities is guided by the Constitution and laws of Ukraine, decrees of the President of Ukraine and resolutions of the Verkhovna Rada of Ukraine, adopted in accordance with the Constitution and laws of Ukraine, acts of the Cabinet of Ministers of Ukraine, and other legislative acts. Thus, the Ministry of Internal Affairs in its activities when creating the 112 system is guided, including by the Convention on the Rights of Persons with Disabilities. |
| ! 13 |
It is proposed in the draft act to provide for the integration into the 112 system of software and information and communication solutions that will ensure the availability of the system for persons with hearing impairments. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. Today, the Ministry of Internal Affairs is considering various options for design solutions to ensure the possibility of calling emergency services by persons with disabilities, including those with hearing impairments. For the optimal choice of such a design solution, it is necessary, first of all, to conduct a study of the functionality of a typical software and hardware complex of the automated workplace of the Operational Dispatch Service of the 112 system regarding the maintenance of emergency notifications and appeals in connection with the need for emergency assistance by persons with disabilities, including persons with hearing impairments with subsequent analysis of such proven solutions and technical capabilities. Thus, the creation of the information and communication infrastructure of the 112 system consists in the introduction of an interconnected set of software products and technical means, which, among other things, will ensure the availability of the 112 system for people with hearing impairments. |
| ! 14 |
It is proposed in the draft act to provide, when creating the organizational and institutional structure of the functioning of the 112 system, the definition of the subjects of the 112 system, taking into account the provision of accessibility for persons with hearing impairment and the procedure for ensuring accessibility for persons with hearing impairments. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 15 |
It is proposed in the draft act, when using terminology, to use the most appropriate term “persons with hearing impairment” instead of the term “persons with hearing impairment”. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. None of the legislative acts of Ukraine provides for the definition of the term “persons with hearing impairment”. In this regard, the terms “hearing-impaired persons” and “hearing-impaired persons” are equivalent. Thus, for example, the order of the Cabinet of Ministers of Ukraine “On approval of a plan of measures to improve access to information of persons with hearing impairments through subtitling and sign translation” of February 25, 2009 No. 209-r, which uses the term “persons with hearing impairments”, is in force today. |
| ! 16 |
It is proposed in the draft act to provide for the establishment of a network of 112 regional centers ensuring their interaction with components or participants that will ensure accessibility for persons with hearing impairments. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 17 |
It is proposed in the draft act to provide, when creating a system of training and retraining personnel in the field of emergency assistance to the population in its training program, the study of the order and features of interaction in emergency situations with persons with hearing impairments. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. |
| ! 18 |
It is proposed to present the thirtieth paragraph of the chapter “Ways and methods of solving the problem” in the following version: “conducting an information campaign among the population of Ukraine to access the 112 system for the entire population without exception”. | First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The term “population of Ukraine” is a set of all individuals residing at a particular moment in the territory of Ukraine and subject to its jurisdiction. Thus, the concept of “population of Ukraine” includes all people, including people with disabilities. In this regard, it is inappropriate to single out individual categories of the population in the draft act. |
| ! 19 |
It is noted that the information and telecommunication infrastructure of the 112 system should include both software and technical solutions for providing access to the emergency care system for persons with hearing impairments and a complex for video communication with a sign language interpreter of emergency services workers arriving at the scene, with persons with hearing impairments, if they are participants in an emergency. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The section “Ways and methods of solving the problem” of the draft act states that the creation of an organizational and institutional structure for the functioning of the 112 system involves, first of all, the implementation of a number of measures at the national level, at which it is supposed to ensure, including the determination of the procedure for the organization of receiving notifications of emergency situations received to the 112 system from persons with disabilities, including those with hearing impairments. Thus, the draft act provides for the possibility of calling emergency services by persons with disabilities, including persons with hearing impairments, who have difficulties in verbal communication. Today, the Ministry of Internal Affairs is considering various options for design solutions to ensure the possibility of calling emergency services by persons with disabilities, including those with hearing impairments. For the optimal choice of such a design solution, it is necessary, first of all, to conduct a study of the functionality of a typical software and hardware complex of the automated workplace of the Operational Dispatch Service of the 112 system regarding the maintenance of emergency notifications and appeals in connection with the need for emergency assistance by persons with disabilities, including persons with hearing impairments with subsequent analysis of such proven solutions and technical capabilities. Thus, the creation of the information and communication infrastructure of the 112 system consists in the introduction of an interconnected set of software products and technical means, which, among other things, will ensure the availability of the 112 system for people with hearing impairments. |
| ! 20 |
We offer cooperation and comprehensive consultations directly from persons with hearing impairments with the All-Ukrainian public organization of persons with hearing disabilities “Ukrainian Society of the Deaf”. |
First Deputy Chairman of the All-Ukrainian Public Organization of Persons with Hearing Disabilities “Ukrainian Society of the Deaf” Tatyana Kryvko (ul. Velyka Vasylkivska, 74, m. Kyiv, 03150) |
Not taken into account. The draft act was developed in order to define approaches to the creation, implementation and operation of the 112 system. Thus, the draft act is only conceptual in nature and does not define the specific organizations, technical means or software products required for the functioning of the 112 system. At the same time, we note that the proposal of the All-Ukrainian public organization of persons with hearing disabilities “Ukrainian Society of the Deaf” to cooperate and provide comprehensive consultations directly from persons with hearing impairments of the Ministry of Internal Affairs has been taken into account. |
Based on the results of electronic consultations with the public, it was decided to reject the proposals sent to the public.
| Acting Director General of the Directorate of Civil Protection, Prevention of Emergencies and Elimination of their Consequences |
Vasyl SKAKUN |
