Q&A: Container weight principles and principals
Samskip Trade Director Caesar Luikenaar answers questions from shippers on the Verified Gross Mass (VGM).
From July 1, 2016, the Verified Gross Mass (VGM) of all packed containers must be known before they can be loaded on board ship. The VGM is established either by weighing the truck-chassis-container combination, or by ‘virtual weighing' - adding the tare weight of the container to its contents. Notification of the VGM will need to be supplied sufficiently in advance to meet the terminal's obligation on closing a vessel before departure.
In all cases, the shipper is responsible for providing the VGM to the carrier.
Q1: Why is the shipper and not the carrier responsible for container weight information?
Misreported or unavailable container weight information has been identified as the cause of a number of ship accidents, some resulting in loss of life or affecting the environment. The Convention for the Safety of Life at Sea (SOLAS) has been amended to reflect the fact that ocean carriers need accurate container weight information to devise stowage plans that ensure ship stability. The only available source of container content weights are the shippers themselves.
Q2: Why can't the carrier or the terminal simply weigh all the containers?
While, in theory, it is straightforward to determine the VGM if the weight of the truck, chassis and fuel is known, Samskip's detailed researches have established that many ports do not have and do not plan to install weighbridges. Furthermore, even where they are in operation, their use requires trucks to enter the terminal in single file, causing a bottleneck that compromises efficiency and may potentially add costs to the supply chain. Wherever allowed, we should avoid physical weighing as every extra container move in the process is adding inefficiency and cost.
Q3: Doesn't the carrier have any obligations covering the VGM under the new rules?
The carrier needs to check that the VGM has been communicated to the party preparing the stowage plan. As such, the carrier has no obligation to confirm that this has been done to the shipper or the authorities, nor to check the correctness of the VGM, nor to weigh the container once a VGM has been supplied.
Q4: But shouldn't the carriers be doing something? After all, it's a ship stability issue.
As Trade Director, I am heading an advisory Working Group here at Samskip that includes representatives from our legal, vessel operations, terminal procurement, customer services, IT and marketing teams, tasked with communicating the impact of the VGM to customers, as well as our own internal processes. We know that, while we do not have a legal obligation to provide or check the VGM, we do have an obligation to make our customers' lives easier, so we are making significant investments in IT to ensure that our systems are capable of managing the full extent of information needed well before the July deadline.
We also know that, in the majority of cases, our customers do have the data required. Wherever possible, we will use online tools to ensure consistency in the information, prevent manual data entry and cover all points in the logistics chain. The Samskip Working Group covers all interests of Samskip and its customers including North Atlantic operations, Intra-European multimodal transport for door-door and for customers with shipper's owned equipment as well as its forwarding arm Samskip Logistics.
Q5: What happens if no VGM is supplied?
The container will not be loaded until a VGM is supplied. If no VGM is made available, physical weighing may lead to a cost, as will administration/demurrage charges, locally-applied fines, etc. With most of our shipments being delivered on a door-door basis, we will be pro-active in preventing containers arrive at the terminal without a VGM. This process will already kick-off right after the loading of a container.
Q6: Who is responsible for enforcement?
IMO rules place jurisdiction at the state level where the container is loaded and sealed. It is anticipated that individual IMO member states will identify Recognized Authorities. The World Shipping Council's position as submitted to IMO is: “A lack of publication of government guidelines and advisories should not be used as a reason by commercial parties not to engage in the planning for the implementation of the VGM requirements.” Local bodies for example are the Maritime and Coastguard Agency in the UK and Inspectie Leefomgeving en Transport (ILT) in the Netherlands. Writing this mid-March we see that in some States it is even now still unsure who and how it will be locally enforced. A situation we monitor very closely.
Q7: I've heard that the Container weight regulations are going to be delayed at IMO. Is this true?
It has been reported that the US and Russian Administrations may propose a delay of entry into force of these regulations by one year, and that these positions are likely to be discussed at the IMO Maritime Safety Committee mid-May. It is also expected that the US will not implement these rules immediately anyway, regardless of IMO. However, other administrations have let it be known that they intend to proceed with preparation work for the introduction of the new rules.
For guidance, the Dutch authorities have been definitive in saying that they will implement the regulation under the current timetable. They have added that they will not proactively check that the legislation is being observed, but will instead investigate whether documentation is in order if something goes wrong.
Therefore one could argue we should just implement it and get it right step by step.
As Samskip adopts a ‘safety first' approach, we continue to consider the July 1 deadline as real.
You can learn all about SOLAS and the Verified Gross Mass here.
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