Just before the new SOLAS Verified Gross Mass (VGM) rule went into effect on July 1, Dan Smith, principal at The Tioga Group took part in a Logistics Management webcast, Are you prepared for the SOLAS container weight rule? During the presentation, Smith outlined numerous “misconceptions” that shippers have about the new rule and walked through the correct approach to each of these issues.
Here are eight misconceptions and the real truth behind each point of concern:
- SOLAS is being put in place to make compliance virtually impossible. “SOLAS is not about shippers,” Smith said, “it’s about ships.” Put simply, the ocean carrier implements SOLAS regulations and provides processes and guidance for their customers to comply. “The Coast Guard or foreign authorities would only intervene if they had reason to believe either a carrier was accepting boxes without VGMs,” he said, “or if a shipper was providing grossly inaccurate VGMs.”
- The new rules are focused on legal issues, and not on safety. According to Smith, SOLAS is intended to prevent careless weight estimates, dishonest estimates, and mis-declaration of cargo. For example, the safety aspects of SOLAS do not require precise weights. In fact, the +/-5% tolerance margin equals 1,500 pounds. “The differences between a container’s stenciled actual tare weight (or between difference dunnage systems) are unlikely to make a safety difference,” said Smith, “and should be immaterial within the aims of SOLAS.”
- SOLAS’ VGM weight rules are extremely complicated. Not true, said Smith, who advised ocean carrier customers to get the necessary weight using one of three methods: • Weigh the loaded container• Weigh the goods and dunnage, add the box tare• Use known goods weight, add dunnage and box tare• Have the terminal weigh the container where available
- The new rule is complex and burdensome. While any new process change can take time for an organization and its employees to adjust to, Smith said the new SOLAS rule is fairly straightforward. Once you obtain the shipment weight using one of the methods outlined above, you can then:Get the signature in one of the following four ways:
• Sign it yourself
• Have someone you designate sign it
• Have someone write your name or designees in block letters
• Use an electronic signatureAnd then, get that information to the ocean carrier via:
• Direct electronic submission
• Third-party electronic submission
• Terminal operator submission after weighing
• Direct paper submission (to be avoided, according to Smith) - The Coast Guard will be looking over your shoulder. According to Smith, the Coast Guard doesn’t intervene in business processes. In fact, it’s not planning to do spot checks. “No agency is going to look over a carrier’s shoulder when it comes to the new SOLAS rule,” Smith said, “but the captain and the carrier are going to be in trouble if there’s no VGM.”
- VGM problems will take months to review and fix. In most cases, SOLAS VGM problems will be resolved quickly, according to Smith, and will take days or weeks to resolve—not months. “We’re talking about an arithmetic problem here,” said Smith, “not an operational change.”
- There are big operational changes in store for global shippers. Quite the contrary, said Smith, who sees the new rules as being more procedural than operational. “Very little will actually change,” he said, pointing out that most shippers already provide weight information of some kind, and most exporters know how much their goods weigh. “If you have a reliable basis for establishing shipment weights you can use it,” said Smith. “If you do not, you need to establish one.”
- If something goes wrong, you’re on your own. Every major ocean carrier has issued VGM guidance, cutoffs, and submission instructions, according to Smith, and multiple service bureaus and third-party logistics providers offer VGM submission portals. “If late container delivery or other issues make it hard to supply VGM before the cutoff, work it out with the carrier,” said Smith, “just like you work out a late cutoff or other exception.”
Ultimately, Smith said the SOLAS VGM rule does little more than solidify the need for safety-related practices that shippers should have been using all along. “I really don’t see much excuse for providing a weight within a 5% accuracy; bathroom scales even do better than that,” Smith said. “It you haven’t been cheating, you probably won’t have a problem with the new requirements.”
This webcast was on Thursday, June 30 2016. You can view the recording on demand here.
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