What Shippers Need To Know About The SOLAS Gross Mass Weight Verification Requirement For Containers

The Maritime Safety Committee at its ninety-fourth session (MSC 94, November 2014) approved for adoption the draft amendments to SOLAS chapter VI to now require mandatory verification of gross mass weight of containers before loading onto vessels for transport. The Maritime Safety Committee also approved draft guidelines which are intended to provide a common approach for the implementation and enforcement of the SOLAS requirements regarding the verification of the gross mass of packed containers. The guidelines were issued in MSC.1/Circ.1475 on June 9th, 2014. The World Shipping Council has also provided a full outline of what the container weight verification regulation will require of each commercial party in the World Shipping Council Container Verification Guidelines.

Why is the SOLAS Gross Mass Weight Verification Requirement for Containers going into effect?

Misdeclared container weights have been historically a problem for the maritime industry as they present problems such as serious ship stability safety concerns for ships, crews, and cargo on board. Port and terminal personnel are also at risk from misdeclared container weights when moving these containers within the confines of their location. The SOLAS gross mass weight verification requirement for containers seeks to address these safety concerns by verifying the gross mass weight of containers so all commercial parties involved in transportation can plan accordingly the safe transport of containers and their cargo.

What are the requirements for shippers to be in compliance?

The new requirement for mandatory verification of gross mass weight of containers can be found in SOLAS Chapter VI, Regulation 2, Paragraphs 4-6.

Methods of weighing containers and their cargo

The new requirement now requires shippers to verify the gross mass weight of a container by the following methods:

1. Using certified and calibrated equipment to weigh a packed container with cargo. The shipper may also use a third party to preform the weighing of the container; or
2. Weighing all cargo contained in packages, which includes the mass of pallets, dunnage and other cargo securement materials to be packed in the container and adding the tare mass of the container to the sum of the single masses. This method can be used by using a certified method which has been approved by the competent authority of the State in which packing of the container was completed. Any third party entity that has conducted some or all of the packing of the container should notify the shipper of the mass of the cargo items and packing and securing material that the party has packed into the container in order to properly facilitate the shipper's verification of the gross mass of the packed container under this method. Cargo weight information between third parties and shippers needs to be effectively communicated between both commercial parties under an agreed systematic form of communication.

It should be noted that estimated weights are not permitted and it is a violation of SOLAS to load a packed container onto a vessel without proper gross mass weight verification. There are no exceptions to this requirement.

Documentation

The shipper is responsible for ensuring that the verified gross mass weight of the container is marked on the shipping documentation. The document can be included with the original shipping instructions to the carrier or as a separate document such as a declared weighing certificate. The gross mass weight in either case should be clearly stated as the "verified gross mass weight" as defined in paragraph 2.1.

The verified gross mass weight in both documentation cases must have a signature from an authorized person by the shipper. An electronic signature is permissible.

Under SOLAS, the shipper will meets its regulatory obligation by providing the verified gross mass weight documentation to the carrier. It is then the carrier's responsibility to relay this information onto the terminal representative before loading onto the vessel. The shipper may also elect to provide the verified gross mass weight of the container to the terminal facility representative upon arrival of the container to the port facility in advance of loading.

Under the new SOLAS verified gross mass container weight requirement there is no definitive deadline for shippers to provide the verified gross mass weight documentation to the carrier. However, the shipper must submit the verified gross mass weight documentation before the carrier's acceptable deadline for use by the stow planner and terminal representative. It is the carrier's responsibility to inform the shipper of what the acceptable deadline is for submission of the verified gross mass weight information. If the shipper fails to deliver the gross mass weight verification document sufficiently in advance to be used in the ship stowage plan, the container will be denied loading onto a vessel to which the SOLAS regulations apply. Any expenses incurred with the non-loading, storage, demurrage or eventual return of the container to the tendering shipper of the container should be subject to contractual arrangements between the commercial parties.

Equipment

In accordance with either method No.1 or method No.2 as discussed above the shipper or the elected third party must use certified and calibrated equipment to weigh a container with cargo. All equipment or other instruments used to verify the gross mass weight of the container, should meet the applicable accuracy standards and requirements of the State in which the equipment is being used.

Possible problems and solutions

Discrepancies in gross mass

Discrepancies that are found between the declared gross mass weight prior to the verification of the gross mass weight are to be resolved using the verified gross mass.

Discrepancies between the verified gross mass weight conducted by the shipper or third party prior to arrival at the port facility should be verified at the port facility and the result be used as the official verified gross weight of the container. If the port facility lacks the proper equipment and instruments to conduct gross mass verification, alternatives means of verification will have to be resolved between the port facility and the shipper.

Containers exceeding their maximum gross mass

As stated in SOLAS chapter 6, regulation 5 "Containers shall not be loaded to more than the maximum gross weight indicated on the Safety Approval Plate under the International Convention for Safe Containers (CSC)." A container that is discovered with a gross mass weight exceeding its permitted maximum gross mass is not permitted to be loaded onto a vessel.

Contingencies for containers received without a verified gross mass

Port terminal facilities that receive containers without gross mass weight verification may arrange for the verification of the gross mass weight on behalf of the shipper pending the port facility has the proper verification equipment and instruments. The verification of gross mass weight of a container can be conducted at the terminal or at another designated location. The method of how this contingency is to be followed should be agreed between shippers and port terminal facilities including costs associated with this method.

When does gross mass weight verification requirement go into effect?

The new SOLAS mandatory requirement for gross mass weight verification of containers goes into effect on July 1st, 2016.

What should shippers do now?

Shippers are advised to begin training personnel on this new requirement and to begin implementing operational procedures that will take into account the container weight verification requirement. Essential training can be obtained through the industry leading CTUpack e-Learning developed by Exis Technologies. Exis Technologies is developing a new module for the CTUpack e-learning course focusing on the container weighing process. The new module will include training on the two methods of verifying the gross mass of a container as a pre-condition of loading on board a ship: either weighing the packed container (Method 1) or weighing all constituent parts in the load (Method 2). For more information on CTUpack e-Learning please contact us.