SOLAS - VGM March, 2016
Agenda Background information Main principles Method 1 Method 2 Method 1 vs Method 2 VGM Information Flow Definition: Shipper? Responsibility Shipper Accuracy vs Margin of Error Timing of Data Carrier depending Penalties FAQ And some advice Contact information
It s all About SAFETY!
Background information MSC Napoli hit by severe storm in 2007 Discrepancies between declared and actual weight of the 660 deck stowed ctrs were identified as contributory factor
Background information In 2014 IMO (International Maritime Organization) adopted the SOLAS (Safety of Life at Sea Convention) to become law on July 1st, 2016 Convention has to be ratified by each signature country SOLAS regulations needs to be implemented in the National laws
Main Principles Packed containers have to be weighed prior to loading aboard the ship The shipper will be responsible for obtaining the verified gross weight (VGM) VGM should be used by the terminal operators and vessel operators in the ship stowage plan Without VGM sufficiently in advance presented, the container will not be loaded
Main Principles Does not apply to: Packed ctr on chassis or trailer for a ro-ro ship on short international voyages; Cargo items tendered by a shipper to the master for packing into a container already on board the ship; Offshore ctrs, as the Convention for Safe Containers does not apply on these ctrs The regulations prescribes 2 methods to obtain the VGM: Method 1 & Method 2
Method 1 Weighing the packed container using calibrated and certified weighing equipment
Method 2 Weighing all packages and cargo items, including the mass of pallets, dunnage and other securing material to be packed in the container and adding the tare mass of the container to the sum of the single masses, using a certified method approved by the competent authority of the State in which packing of the container was completed. (FIATA)
Method 1 vs Method 2 Bulk Tank(s): You Must use Method 1 to provide a VGM to the carrier Cargo related: for scrap metal, unbagged grain, unbagged bulk cargo, Method 2 is inappropriate and impractical
VGM information flow
Definition: Shipper? A legal entity or person named on the bill of lading or sea waybill or equivalent multimodal transport document as shipper and/or who a contract of carriage has been concluded with a shipping company. The shipper may also be known as the sender. (IMO & WSC Guidelines) To think about: what about forwarders? what in case of consolidation?
Reponsibility Shipper Verify VGM Communicate VGM to the shipping line or terminal representative Can be in shipping instruction Or seperate message such as weight certification Or EDI message Signed by somebody duly autorized Responsible Party Sufficiently in advance to be used in stowage plan
Accuracy vs Margin of Error Accuracy: all VGM need to be obtained by using weighing equipment that meets the applicable accuracy standards and requirements of the local governments. This is an international requirement. There is no provision in the SOLAS VGM requirements for any margin of error, tolerance or accepted variance percentage. SOLAS embodies a physical weighing requirement, not a system of estimation.
Accuracy vs Margin of Error However, enforcement agencies may exercise discretion or tolerance in deciding when to initiate further investigations or penalty action. However, if a shipper is merely estimating the gross mass and hoping to fall within any government enforcement tolerances, it would be violating the SOLAS requirements. There are no exemptions from the requirement to weigh using either Method 1 or Method 2.
Timing of Data VGM data must be provided to the carrier prior to arriving on the pier No VGM equals no Gate the standard Updates to VGM? Yes, when container has not been loaded on board vessel any further updates to VGM are not permitted planning and stowage has already been decided 1 July 2016: but think about transhipments & containers placed on quay before, but loaded on board after! Each Carrier will implement their SOLAS program by vessel
Communicating the VGM Process The VGM is to be provided to the carrier preferably by electronic means such as EDI or EDP or through an e-commerce platform like INTTRA, and to the terminal representative sufficiently in advance of ship loading to be used in the preparation and implementation of the ship stowage plan. EDI Message Vermas Verified Mass Message
Vermas Communication Message The Shipper will need to Container number(s) & VGM (By container) Responsible party (named person) Method used ( conditional) The Vermas message will be sent to the carrier ( EDI or PDF) with transportation details prior to container arrival at load port
Carrier depending The VGM is required in order to prepare the stowage plan of the ship prior to loading. Deadlines will differ according to a number of factors. Tips for shippers: Obtain information on documentary cut-off times from the carrier in advance of shipment.
Carrier depending The Container shows three weights on the container doors: 1. The Maximum Gross Weight (MGW) which is defined as the weight of the Cargo together with the weight of the container (known as the TARE weight) which must never be exceeded. 2. Tare Weight: weight of the empty container 3. Payload = MGW -Tare Weight
Container Tare Weight
Tips - Practice Import side of the Transaction Suppliers ensure that discussions have taken place to ensure that communication of data is understood Review all EXW transactions and who is the party noted on the bill of lading
Tips - Practice For exports Suppliers: check if all weighing devices are calibrated and certified according to local regulations Exporters: review who has the carrier contract and/or is the party mentioned as shipper in the B/L Do not wait for countries to publish their guidelines to start your program to manage the data. A country guideline will not overide the SOLAS regulation
Penalties As a national issue, fines and other penalties will be imposed under national legislation Enforcement agencies may implement measures to satisfy themselves that compliance is achieved, which might be expected to include documentation checks, auditing or random weighing.
FAQ Is there a format to communicate the VGM? Is there a deadline for when the information must be received by the carrier and terminal operator? Who will pay for the weighing of method 1? Where can I find a list of publically available weighbridges? Our company only ever provides part loads/lcl. What is our position?
In short Source: http://www.joc.com/sites/default/files/u1390826/joccontainerweight-infographic-1215-v5_1.jpg
And some advice The shipper remains responsible, but there is a lot that needs to be negotiated between the different stakeholders of the global freight forwarding use this opportunity to strengthen your relations with your freight forwarders and carriers.
BDP International thanks you for your time and participation. If you would like to be added to our distribution list and receive the invitation for future webinars, please send an email to: natalie.mortelmans@bdpint.com
SOLAS - VGM March, 2016