SOLAS Container Weight Verification – Update May 9, 2016
SOLAS and Verified Gross Mass, what is it?
In November 2014, the International Maritime Organization (IMO) amended the International Convention for the Safety at Sea (SOLAS), Chapter VI, Part A, Regulation 2 to require that a packed container’s gross mass (Verified Gross Mass, or VGM) be verified prior to loading and stowage aboard a vessel. The new rule goes into effect on July 1, 2016 in all 171 IMO member countries, including the United States.
Why is this important to IMO member countries and the global supply chain community?
It is simply a matter of safety for all those involved in the supply chain, from truckers, to terminal operators, stevedores and anyone else exposed to loaded containers. It’s also critically important for vessel operators to have accurate weights for their laden containers to accurately and safely stow containers on their vessels, and for the vessels themselves to sail safely. Misdeclaration of weight is still a problem around the world, and the goal of the amendment is to eliminate this for all stakeholders.
Who is responsible for providing the Verified Gross Mass (VGM) and to whom:
The SOLAS amendment provides that the “shipper” be solely responsible for verifying the Verified Gross Mass (VGM) and transmitting that information to the vessel operating common carrier prior to vessel load.
What methods can be used to weigh a container to provide the VGM to the carrier?
There are only two (2) ways that shippers (or third parties working on their behalf) can weigh the container for the VGM:
1. Weighing the container after it has been packed using a scale that is both calibrated and certified, or…
2. Adding the weight of the cargo and the container’s tare weight. However, certain commodities by nature of how they’re shipped cannot be weighed using method 2 (metal scrap, plastic scrap, dry bulk grains, and other bulk cargo).
How will a shipper know the tare weight of the empty container?
Carriers have informed the shipping community that they will accept the tare weight written on the side of the individual empty container, or in many cases, carriers will provide the tare weight for the specific container being loaded on their website.
Will the railroads load a container on the rail without VGM?
Yes. The IMO guidelines apply to ocean carrier and ocean terminal operators, rather than railroads.
How and when will a shipper communicate the VGM to the carrier?
According to the regulations, the VGM can be submitted either electronically as an EDI message (an EDI message called VERMAS with a code of 304 has been established for VGM), via electronic portals used by carriers, or through a carrier’s own electronic portal. The weight certification must be signed by a person duly authorized by the shipper (an electronic signature is acceptable). Ocean carriers in the United States have messaged the VGM “cut-off” will be noon on the same day as the receiving cut-off time. Laufer will confirm VGM “cut-off” at the time of booking.
What happens if the container arrives at the ocean terminal without VGM?
Each terminal will have their own policy; however, the majority have implemented a “no doc, no gate” policy, whereby a container without VGM will not be allowed into an ocean terminal. In some cases, the container may have to be picked up and trucked to a scale for VGM and then returned to port.
Do any terminals offer weighing services?
Yes. Baltimore, Charleston and Savannah will weigh the container for a fee. USWC ports have stated that they will not offer weighing services.
What if the weight verification is inaccurate or late?
Carriers in the United States are messaging that without a VGM prior to loading by the specified VGM cut-off, they will maintain a no-load policy and containers will be held in limbo at the receiving terminal until an accurate VGM can be provided. Demurrage and/or any other cost incurred by the carrier to move the non-verified container within the terminal as a result of an inaccurate or missing VGM will be on the account of the shipper. At this point, we are not seeing any “fines” associated with this should an inaccurate or late VGM be provided.
What does accurate mean?
The SOLAS amendment calls for the VGM to be accurate (cargo weight plus tare weight). Many IMO member countries are in the process of declaring what is within an acceptable tolerance to be allowed to load on a vessel (Japan is considering +/- 5% range for example, in India it is +/- 200 KG). There is no such “allowable” tolerance in the United States as of yet.
Are carriers, terminals, ports, and member countries all aligned on procedural implementation and interpretation regarding the SOLAS amendment?
Not yet. Very few IMO member countries have issued formal guidelines or regulations regarding the SOLAS amendment. Each member nation has very different infrastructure and methodology to provide verified and accurate weights of loaded containers, and processes to handle export containers.
Will the implementation date of July 1, 2016 be delayed?
We expect this to go into effect as planned on July 1, 2016.
What can Laufer Group do to assist?
We are here to help. At Laufer Group we fully support the intent of the amendment and agree that providing accurate container weights is critical to the safety of all of us in the supply chain. We are expecting this to go into effect as planned on July 1, 2016 so we recommend that our clients start the VGM process at the beginning of June so that we can work through the process prior to the implementation date, and despite the uncertainty and various degrees of industry preparedness, we are prepared to support our US export customers by:
1. Consulting on which method is best for each customer and for each loading location
2. Preparation of the VGM template required for each container
3. Weighing through third parties of loaded export containers
4. Submitting the VGM timely to the ocean carriers
5. Providing updates on the SOLAS amendment implementation
For any additional information or guidance on your program and what you need to do to be in compliance with the SOLAS amendment, please contact your local Laufer export customer service support team. Thank you so much for all your support and we look forward to being your partner through this new process.
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