TT Talk - Verification of container weight: the starting gun has been primed - on your marks!
On 20 September 2013, the IMO Sub-committee on Dangerous Goods, Solid Cargoes and Containers (DSC) agreed a revision to the SOLAS convention to mandate the verification of gross mass of containers prior to loading on board a ship.
The Sub-committee also agreed accompanying guidelines, which cover what have emerged as the difficulties in implementing throughout the industry and the way in which the change can be enforced.
This decision marks an important milestone in a debate that has been going on within the industry for many years and at IMO for the last six.
The debate about container weighing has divided the industry. Even within the shipper and forwarder communities, there are very different perceptions as to whether the proposal is appropriate or proportionate. On one level, there should be no issue, since the relevant legislation already requires the shipper to provide cargo information to the 'master or his representative', including a description of the contents and declaration of gross mass. Further, the provision already requires the shipper, prior to loading cargo units on board ships, to ensure that the gross mass of such units is in accordance with the gross mass declared on the shipping documents.
The fact that
a limited number of casualties revealed that, while not necessarily causative of the accident, a statistically significant proportion of containers carried had a materially different gross mass to that declared on the ship's manifest
is not always viewed as convincing. No information is in the public domain as to whether those responsible for misdeclarations have been subject to regulatory censure or penalties from the shipping lines. However, the accepted assumption is that regular FCL (full container load) shippers habitually declare gross mass accurately. Equally, trades in homogenous cargoes (for example tea or coffee) are likely to have known weights, even where there may be less sophisticated means of measurement. Thus, the major issue would appear to be for specific trades (such as scrap materials), groupage/LCL (less than container load) shipments and those initiated by those that ship irregularly.
For those who have been used to declaring gross mass accurately - if not at the time of booking a container, then at least 'sufficiently in advance' to allow effective ship stowage planning - the change may appear irksome. In future the shipper will be required to secure a 'verified' gross mass of the container either by weighing the packed container or by calculation. This alternative, put forward by the German delegation to the IMO, relies on an improved, more reliable version of the current process, whereby those responsible for packing the container calculate the mass of each item of cargo stowed in the container, plus the mass of pallets, dunnage and other securing material. When added to the known tare mass of the empty container this would produce an accurate 'gross mass' of the packed unit.
The verified gross mass will be required to be stated in the shipping documentation and presented to the 'master or his representative and to the terminal representative' to be used in the ship stowage plan. Should the verified gross weight not be available, the packed container will not be loaded on to the ship.
There are, in reality, just two additional steps - a verification process and a prohibition to load if the information is not available.
What does this mean to the containerised freight industry?
From a pure safety perspective, it is important that the gross mass of the packed unit is established before the journey begins. Because there are the two options, so long as the packer has an approved process, it is entirely possible for this to be done. Obviously, this can be supported by existing or emerging technologies - for example, traditional weighbridges or trailer fitted compression sensors, amongst others. The accompanying guidelines leave it with the competent authorities in any country where containers are packed to approve the packer's chosen methodology. Every shipper and forwarder should therefore consider whether it is appropriate to go through an approval process as defined by the relevant authority or to contract with another party to verify the gross mass at a point after the container has been packed.
For many, the existing processes may be robust enough to deliver a verified gross mass.
The contents of a packed (and sealed) container should not change during the journey, which means that having a process of weighing at or near the port remains a valid solution - so long as the information can be fed in a timely fashion into the ship stowage plan. Some argued that a deadline should be specified in order to improve clarity of information flows, but this proposition did not find favour due to differing trade practices around the globe. Moreover, this may be academic since more jurisdictions require advance cargo information at least 24 hours before sailing.
Clearly timeliness is important, but accuracy is the issue.
Importantly for the supply chain industry, DSC 18 also agreed to submit the draft CTU Packing Code, to be finalised by the IMO/ILO/UN ECE Group of Experts in November 2013, direct to MSC 93 in May 2014 for approval. These two changes, taken together, surely provide an opportunity for packers and forwarders to look to develop differentiated services as the world moves towards an improved level of competence. Implementation for both weighing and packing is currently scheduled for July 2016.
This is an important 'direction of travel' as the industry will be able to move to substantiate the trust that has to be inherent through the supply chain
, but is stretched by each reported maritime incident - of which we have seen too many in recent months.
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