TT Talk - Weighing in – again!
The TT Club, as a leading liability and equipment insurer through the supply chain has been a proponent of ensuring that containerised cargo weight declaration is accurate. This item provides feedback on the TT Talk survey carried out in July 2011. While the survey did not capture details about the respondents, such as from what part of the industry they came, separate email correspondence evidences that there was representation across the industry, from liner operators, forwarders and terminals.
In summary, the results seem to suggest a 50:50 division of whether units declared as empty should be exempted from weight verification, but a substantial majority in favour of a reasonable, but modest, tolerance between declared, certified and actual weight being allowed and also strong agreement that verification of weight needs to be done at the earliest possible point in the transport chain (such as the point of packing or consolidation). In a similar way, the majority believe that it is effective for the certified weight receipt to accompany transport documentation.
The specific responses are:
1. Should units declared as empty be exempted from weight verification?
53% believe that these units should not be exempted.
2. Is it appropriate to insert a reasonable, but modest, tolerance between declared, certified and actual weight?
70% agreed that a modest tolerance should be allowed.
3. Do you agree that verification of weight should be done at the earliest possible point in the transport (such as the point of packing or consolidation)?
88% agreed that weight verification should be done in this way.
4. Is it effective for the certified weight receipt to accompany transport documentation? 81% thought that a certified weight receipt should accompany documentation.
The matter was discussed at the relevant IMO sub-committee in September 2011 and it has been left with the World Shipping Council to lead an informal correspondence group in order to identify what specific legal change is required and develop practical guidance as to how the change can be implemented and enforced. It is, of course, critical that all those interested in the supply chain and affected by any proposed change in regulation have a ‘seat at the table’. Thus, apart from liner shipping companies and Maritime Administrations, there will need to be representation from shippers, forwarders, consolidators and terminals. And, of course, a broad spectrum of insurers will also participate. This work will be brought back to the sub-committee in September 2012 and – assuming that there is agreement – will then be proposed to IMO’s Maritime Safety Committee in May 2013 for implementation.
Some feedback suggested that it appears wasteful to weigh empties, but there is recognition that accidents occur arising from mistakes, as with 'Husky Racer'. While processes may well have been modified in the light of that accident, the boxes were apparently moving on an 'internal' empties repositioning. Thus, while that issue might well have been resolved, there has to be a residual concern that a defined exemption would create potential security vulnerability.
In any event, assuming the law is changed, it may be that the industry will rapidly reach a position where all units are in fact check-weighed as an integral part of handling. Although the challenges of system integration are not slight, the very nature of such work is likely to result in automated data capture - and twistlock load sensing technology appears to be in pole position for this, providing load eccentricity as well as pure mass. Such automated data capture integrated with booking, TOS and ship planning data will clearly facilitate appropriate alerts when any unit is recorded as being outside tolerance for the expected mass, whether empty or laden and also whether import or export.
The practical guidance will need to canvas a number of important issues, including how to verify weight at the point of packing and what happens when a unit is found to be outside tolerance at a check-point. Whatever detail is compiled, the result should be a welcome sharpening of the existing legal teeth within SOLAS, the relevant maritime regime.