Strainstall has compiled a list of the key frequently asked questions relating to the implementation of the new SOLAS container weighing regulations.
The international convention for the Safety of Life at Sea (SOLAS) is an international maritime treaty to ensure the safety of the ship, the safety of workers both aboard ships and ashore, the safety of cargo and overall safety at sea. The treaty has been recently amended (chapter VI, part A, regulation 2) to require (by law) that packed containers' gross mass are verified prior to stowage aboard ship. This legislation covers all SOLAS regulated vessels, which is 98.6% of the world's tonnage.
The IMO's SOLAS amendments provide two approved methods in determining the container weight:
- Method 1 - weighing the loaded container
- Method 2 - weighing the contents of the container and adding those weights to the containers tare weight
If the new regulation is clear, at least in principle, on what needs to be done to achieve compliance, it is also unambiguous on who is ultimately responsible: Container VGM determination can be subcontracted to a third party by the shipper, but the shipper remains responsible for regulatory compliance.
Under the SOLAS requirements, the shipper named on the ocean bill of lading is the party responsible for providing the maritime (ocean) carrier (master) and the terminal operator (terminal representative) with the verified gross mass of a packed container. The carrier and the terminal operator must not load a packed container aboard a ship unless they have the verified gross mass for that container.
Due to the complexity of the international supply chain, the entity identified as the shipper on the bill of lading may not have direct or physical control over key elements of the process by which verified gross mass is determined. A shipper in such circumstances should be aware of their responsibilities and ensure that arrangements are in place to obtain and provide a verified gross mass in compliance with these international and national regulations.
Download Strainstall's 2016 container weight verification technical paper (5.5MB) to learn more.
SOLAS does not instruct any particular form for communicating the verified gross mass of a container. The VGM information must be signed and dated by the shipper or a person duly authorised by the shipper. Signatures may consist of the last name of the responsible person in capital letters and can be exchanged electronically.
As an international issue, SOLAS regulations state that VGM weighing equipment, for both method one and two solutions, must meet national certification and calibration requirements. There is no provision in SOLAS for any margin of error.
Shippers using compliant weighing equipment and procedures will obtain VGM values that are well within any national tolerances adopted for enforcement purposes.
The new ruling will be officially enforced by the maritime authorities of individual nations, whose implementing regulations will vary depending on country and region. The real-world enforcement seems most likely to be carried out directly by the container lines and terminal operators, who are obligated not to load a container without the certified VGM document accompanying it. National enforcement agencies may implement measures to satisfy themselves that compliance is achieved, which could include documentation checks, auditing or random weight checks.
Compliance with this obligation by the carrier and terminal operator may result in commercial and operational penalties, such as delayed shipment and additional costs if the shipper has not provided the verified gross mass for the packed container. As a commercial issue, penalties may involve repacking costs, administration fees for amending documents, delayed or cancelled shipments.
Although the shipper is ultimately responsible for declaring the verified weight of a container, the new amendments will affect and therefore apply to everyone within the supply chain. Shippers, freight forwarders, vessel operators and terminal operators will all need to establish procedures to ensure the implementation of the SOLAS regulatory change.
The SOLAS rules require the shipper to communicate the verified gross mass as part of an official shipping document. It must be signed by a person duly authorised by the shipper, with a first and last name, not just a company name. The signature may be an electronic signature or may be replaced by the name in capitals of the person authorised to sign it.
The VGM and signature can be part of the shipping instructions communicated via electronic data interchange (EDI), or be contained within a separate communication including a hard copy document. In either case, the document should clearly highlight that the gross mass provided is the verified gross mass.
While the onus is upon the shipper to fulfil the container weight verification obligation, the most practical location at which weighing can take place is at the ports and terminals, where lifting is a part of the existing cargo handling process.
Strainstall’s Container Weight System™ enables the weight of a container to be determined without the need to do anything different to what ports and terminals do today, the weight is obtained during the course of existing lifting operations. Spreader based weighing solutions are the only solution that have zero time and operational impact on existing terminal operations.
There is no need to implement separate lift and drop or more complex weighbridge based processes. This gives ports and terminals the opportunity to obtain a VGM for each container without any additional operational cost If a container turns up to a terminal without a verified weight it cannot be loaded onto the vessel. By installing a container weighing system on site, any potential issues of containers being stranded at the terminal need not be a worry.
The SOLAS regulations provide that verified gross mass shall be obtained under both method 1 and 2 by using weighing equipment that meets the applicable accuracy standards and requirements in the State in which the equipment is being used. Those national standards and requirements will determine the acceptable level of accuracy of the weighing equipment used.
There is no single international approval for weighing equipment to provide accurate VGM, however, all equipment used (whether for method 1or method 2) will need to meet the applicable accuracy standards and requirements of the state in which the equipment is being used.
NOTE: Strainstall's CWS™ has successfully achieved EU-type approval, ensuring full SOLAS compliance.