You may have heard that effective July 1st, the International Maritime Organization has amended the Safety of Life at Sea (SOLAS) convention, and new rules will be in effect for reporting of verified gross mass (VGM) of containers. To help you prepare, here are 5 things you should know:
WHAT DOES THIS MEAN FOR ME AS A SHIPPER?
Before a packed container can be loaded onto a ship, its verified gross mass must be determined through weighing; currently there is no exception to this requirement.
A. WHAT ARE THE ACCEPTABLE METHODS FOR DETERMINING VERIFIED GROSS MASS (VGM)?
Method 1: Weighing/scaling the fully loaded container using calibrated and certified equipment; or
Method 2: Weighing all packages and cargo, including pallets, dunnage and any securing material to be used in loading the container and adding those weights to the tare weight shown on the container’s exterior.
B. KEY POINTS:
- Accuracy is currently the only concept with which the shipper needs to be concerned – this is a physical weighing requirement and estimating of weights is not permitted
- All equipment used must meet the accuracy standards and requirements of the State in which the equipment is being used.
- The only exception is “Individual, original packages that have the accurate mass of the packages and cargo items (including any other material such as packing material and refrigerants inside the package) clearly and permanently marked on the surface, do not need to be weighed again when they are packed in the container. A good example is a flat screen TV that has their weight (e.g. X kg) marked by the manufacturer on the box”.
- SOLAS requirements will apply to both FCL and LCL shipments.
WHAT HAPPENS IF THE VGM IS NOT PROVIDED AT THE DEADLINE REQUIRED BY CARRIER? WHEN IS THE DEADLINE?
It is currently a violation of SOLAS to load a packed container aboard a vessel to which SOLAS applies without a proper weight verification. There is currently no exception to this requirement. In the absence of a shipper providing a verified gross mass of a packed container, that container “shall not be loaded on the ship”. Shippers should obtain information on documentary cutoff times from their carrier in advance of the shipment.
HOW CAN RCL HELP YOU BE COMPLIANT?
- RCL can assist with recommendations of Certified Scale Companies in your area
- RCL can review your submitted documentation and communicate to your nominated personnel SOLAS requirements to ensure the Verified Gross Mass and appropriate signatures are included. Thus, avoiding rejection of the container upon arrival at the port for non-compliance of SOLAS
- RCL can investigate opportunities to scale your container at the receiving port. If service is available, RCL can implement the process on your behalf.
WHAT ARE THE DOCUMENTATION REQUIREMENTS?
Shipper’s weight verification is compliant with the SOLAS requirement when it is “signed”, meaning by a specific person representing the shipper and is named and identified as having verified the accuracy of the weight calculation on behalf of the shipper. The shipping document shall be (1) signed by a person duly authorized by the shipper and (2) submitted to the master or his representative.
HOW CAN RCL HELP YOU?
- RCL can submit your signed documentation in a timely manner as required avoiding possible rejection of container loading under the new SOLAS requirement.
- RCL can capture the VGM data you provide and present it varying reporting processes to assist management in quarterly / year end analysis and compliance.
- RCL’s seasoned staff is cross-trained to communicate and educate; first and often with our clientele.
HOW WILL THIS BE ENFORCED? WILL THERE BE PENALTIES APPLIED?
Nationally legislated enforcement agencies may implement measures to check compliance, such as documentation checks, auditing, or random weighing. Enforcement policies may require shippers using method 1 to produce weight tickets or other documentation upon request. Fines and other penalties could be imposed under national legislation. Penalties could include repacking costs, administrative fees, demurrage and delays or cancellations of shipments. If the shipper has not provided a VGM, the vessel master should not load the container, and additional costs such as pier demurrage, roll fees etc. could occur. The new SOLAS requirements apply equally to both under and overweight containers.
WHO IS RESPONSIBLE FOR COSTS FOR THIS NEW REQUIREMENT?
Since the shipper is legally responsible to obtain and provide the verified gross mass, it may be expected that any third party service provided would seek re-reimbursement of the cost of weighing; this is Commercial issue and will be a matter to be determined by the parties involved.
As with any new regulations, we can expect there to be further updates and amendments to SOLAS as we approach the effective date and thereafter- be assured that RCL will continue to monitor implementation of this new SOLAS amendment as it evolves. With over 30 years experience in International Transportation, you can count on RCL Agencies to guide and assist with all your transportation needs while providing the right solutions at the right time!