With the SOLAS VGM deadline looming, more and more people are starting to get nervous about the whole issue in general and SOLAS VGM Method 2 in particular..
If you have been living underwater for the past few years and not aware of what SOLAS VGM Method 2 is all about, don’t worry, have a look at this article before you proceed further..
The questions I have been receiving from many readers in relation to Method 2 are :
- Will the 3rd party assessors VERIFY THE WEIGHT or VERIFY THE PROCESS OF WEIGHING
- Why must the shipper be accredited
- Can the packing station do the actual weighing or is the shipper expected to do it
- Should the shipper and packing station both be accredited
- If the shipper doesn’t want to be accredited since the packing warehouse is, can he still
be shown as the shipper on the BL
I discussed these questions about SOLAS VGM Method 2 and how it will work in South Africa, with Christopher John Walden of Supply Chain Compliance Services (SCCS), who are one of the 3rd party assessors in South Africa appointed by SAMSA..
Below is his guest post covering all above questions and more..
As a 3rd party assessor appointed by SAMSA,
What we verify
- We verify that the company that installed the scales/weighing device is accredited by SANAS
- We verify the system this company follows in weighing/packing and obtaining the VGM
- We verify that the weighing equipment/scale type used by this company is registered with NRCS
What we don’t verify
- We do not verify the weight of the cargo
- We do not verify the certification of the weighing equipment used, but we want to see the certificates used to confirm the accuracy of the weighing equipment
- We do not verify the calibration certificates, but we want to see the certificates to confirm the accuracy of the weighing
- We do not verify the certificate of the person doing the calibration, but we want to see the certificate to confirm the accuracy of the calibration
Who needs to be accredited – the shipper or packer or both..??
The shipper definitely needs to be accredited because they are the responsible party as per the SOLAS convention to ensure that the weight of the container is declared correctly.
Although some of the packers are also accredited, as the name implies, the “packer” is simply that. They are there to pack the cargo into the container.
But the packer also has a responsibility in this chain and needs to
- make sure that the weights of all the cargo, dunnage, pallets, strapping and any other packing/securing materials are entered onto a packing list or some other form of document
- add the total weight of the cargo and packing material inside the container to the TARE weight of the container to calculate the VGM.
If the packer is a third party, there needs to be an agreement in writing between the shipper and the packer to cover above.
If the shipper packs their own product, they are both the shipper and the packer and are therefore responsible to calculate the VGM and update same in the port system (NAVIS) for export of containers.
Regarding the question about the shipper not wanting to be accredited but still appear on the BL, because the packer is accredited — My answer would be NO, it is not possible.
The packer could possibly be a groupage shipper and accredited in his own right as his name would appear on the Master bill. But if you want to be on the bill as the shipper you need to be accredited.
Is the Shipper accreditation a lengthy process..??
Accreditation of this shipper need not be a lengthy procedure as many fear.
- Firstly we look for the agreement between the shipper and the packer
- We then take the packers accreditation number into account and do a physical check of their procedures like
- whether they include that particular cargo type
- or a physical check on the weighing equipment and
- look at the training records
If a packer has already been accredited , we cannot just take this accreditation and simply offer a new shipper his accreditation. We need to still look at the packer’s procedures and verify that these procedures are suitable for the cargo the new shipper requires.
There can also be an agreement between the shipper and the packer , whereby the packer would be the name on the BL, (this does happen) and they have an internal agreement in place covering the legal side of this arrangement.
As a SAMSA accredited third party we check
- compliance to the SAMSA mandate (Marine Notice 25 of 2016)
- traceability, responsibility and a verifiable paper trail to show how the VGM is achieved
- proof that the staff who are involved in the process are competent in the position they hold
- this needs to be proved by records that show the training, toolbox talks, one on one instructions
- all of which may possibly have been done verbally but needs to be backed up with a signature of the staff showing understanding
- the actual packing of the container to verify that the procedure documented is the same as the actual method used and the CTU code of practice is being followed
Load planning which is so often missing is an integral part of making sure that your container
- is balanced,
- has a low center of gravity,
- is packed safely so as to minimise any shifting of cargo and
- there is no danger to persons receiving the cargo.
The aim is to lift the level of competency in the entire supply chain and hopefully we are all helping to reduce the accidents that plague our road, rail and shipping industry.
What has been your experience with regards to SOLAS VGM Method 2..?? Are things clear or are there still doubts/questions..??
If you wish to contribute guest posts to this blog, let me know and if the post is suitable to this blog, and the Guest Post Guidelines have been followed, I will publish it..
this is my experience with VGM method 1.. the procedures make us documentation team headache.
Load port said that we must submit the weighbridge ticket within 48 hours prior vessel ETA , which they never inform during the workshop.
Load port only accept their own port weighbridge. As a result, this will incur extra charges for shipper as normally we will weight the cargo at our own premise or stuffing site.
Also the transporter will claim the standby hour while waiting their turn to weight.
One more, we need to fill in VGM form and submit to liner and transporter with every of the form is different style and format.
Such a waste of time, wonder why they never standardised the form to ease the shipper. I bet many more issues to come afterward……
Hello Josphine, which country are you based in..??
Hi Hariesh, we based in Bintulu, Malaysia..
I genuinely feel that many in the industry will reap of the benefits from this new method of weighing goods. Some might argue that it brings even more bureaucracy, but I definitely feel that it will only foster clarity on the long run. And yes Owen, good point you make their, not all ports can: especially ports in located in the Caribbean.
Thanks for your views Jonas..
I agree with Delan, why not just make the ports responsible , the shipping lines are their clients afterall, it would be easy ,but I think the reason is that
a] not all ports can
b] they dont want to be legally liable……the risk is too high ….
c] it is my understanding that the “scales “used by gantry and reach stackers are “load limiters ” and are not type approved scales and as such are less accurate.
d] making the shipper responsible shares out the liability and costs of accurate weighing.
Having said that ,the USA is negotiating to do just that and it will be interesting to see the outcome, especially as we have invested capital in scales and reach stackers and mobile “come to you units ”
.
rgds Owen
Hi Owen, the cargo is packed by the shippers (or their packers), the cargo belongs to the shippers.. It is this logic the IMO is using to make the shippers responsible for the declaration of the correct weight.. Rightfully so.. So why should the port or shipping line be responsible for this..??
No one else other than the shipper will know how much weight has been packed in their container and if all the shippers took it upon themselves to be responsible in their declarations, this whole issue would not have occured..
Here in the USA, the shipper has always reported the weights to the carrier 2 days before the vessel sails or the cargo is not to be loaded by the port. Since they have ALWAYS had this information, plus have always had the tare weight of the containers, it should not fall to the responsibility of the shipper or the customer to be liable for the VGM. This should be a port operator responsibility / liability. The fault that the ports failed to add the two weights together is not fault of shipper or customer arranging their own freight.
Hi Veridicalangel, the question is “was the weight reported by the shipper to the carrier” a weight that has been verified by someone other than the shipper or is it only the shipper giving this weight..?? If it is the former, then such weights maybe considered VGM.. If it is the latter, then not..
Hi Julia,
If you are still confused mail Hariesh and he will forward my mail address and phone number to you and I will assist.
Chris Walden
Hi
I am using method 2 when stuffing containers for our reefer train project from Limpopo to port ,at the beginning it was a bit of time delay .But it has become much of a habit now so all is good.
Great to hear that Robin.. Yes there will be teething problems, but in the end it is a requirement to ensure everyone’s safety..
Greetings Hariesh!
Thanks for the blog and all the knowledge you share with us… Be blessed always!
As a shipper we are still puzzled and have no clue where to begin with this new regulation.
We pack our containers for exports (no packers involved) – we are and will always be the shipper on the BL’s
So next time we pack for export what must we do to ensure that we are complying with the Solas container weighing regulations?
Will we receive a document from our forwarding agent? Or must we start the accreditation procedure with the assessor now?
Thank you for your responses!!!
Hello Julia, you can use Method 2 whereby you can weigh your cargo individually + cargo packing material weight + tare weight of container and that is your VGM for which you have to be accredited as per process mentioned in the article.. Or you can use Method 1 using one of the weighbridges on the NRCS website.. 🙂
i have a different view on SOLAS, the requirement in SOLAS is to ensure that all containers loaded on board has a VGM and that the shippers are made liable for the weight (VGM)declared by them.
Hence I believe that requesting or setting a guide line as to how the cargo should be weighed is not needed, why ? since the VGM declared by the shipper becomes ‘Null and Void’ against the VGM taken at the terminal, the final weight that is going to be accepted by the vessel is the VGM produced by the terminal, as such there should not be any conditioned laid on how the shipper should weigh the cargo, instead it should remain as it is, where the shipper declares the VGM through the SI (shipping instructions) and once the container is weighed at the terminal and should there be a variance exceeding the SOLAS guide lines it could be either accepted or shut-out.
In the event it is accepted then the VGM would be amended to the weight taken at the terminal, in the event the shipper wants to challenge same, they could do another weighing, also if SOLAS needs accountability, they could regulate the SI as a lawful document and request that an authorized person sign the SI, this system would ensure that the shippers would declare the VGM on the SI with responsibility.
As an example, I like to refer the system practiced in the Air Transportation, as you would agree, safety is paramount in Air Transportation too, as such all of the shipments carried by air is weighed by the ground handling of the airport and the final weight declared to the respective flights are the weights taken by them, so simple.
With the new guide lines on SOLAS we will have another cut-off imposed by the carriers, they would surely want the containers early at ports to ensure that they have the VGM on all containers before the stowage plan could be done.
I would appreciate to have your taught s on this suggesting.
Hi Delan,
Your comments are noted with interest. The method to which you are referring is method 1. The problem there is that the coastal post of South Africa do not have the necessary weigh bridges and do not offer the service. the weighing of full containers is only offered at some of the inland terminals. Thus it is necessary for containers to have a VGM prior to being delivered to the coastal port in South Africa.
The article written was as to how South Africa is handling the method 2.
Hello Delan, thank you for your comments.. The main issue that MOST countries around the world are facing with regards to SOLAS VGM is that not all ports are equipped or are doing weighing of containers.. There are few exceptions like Felixstowe, Singapore that are weighing in the terminal, but majority of the worlds ports are NOT weighing containers in the terminal.. Therefore it is essential that either Method 1 or 2 is followed by the customer outside of the port..
As advised by Alexander, in the case of SA, there are not enough weighbridges in the country to handle this and therefore Method 2 seems a better option for many..
In terms of using SI weights as VGM weights, there is a big problem in that.. The SI only has cargo weight and doesn’t include Tare weight of the container.. SOLAS VGM requires the total gross weight of the container including tare weight so there is no way the SI weight can be used and further more, SI weight is NOT verified, it is just a weight on paper..
In regards to the comparison with Air Freight, the reason Air Freight weights are regulated is that the air freight charges are collected basis weight where as seafreight rates especially for FCLs are per box.. 🙂