Donna Lemm, vice president of global sales, offers insight into the IMO weight regulations.
Article originally published and courtesy of JOC.com.
As the industry catches its breath after the struggles on the West Coast, we are less than a year away from a potential new risk of long lines and more confusion across the U.S.
That risk is the lack of clarity regarding the implementation of the IMO Solas Amendment (Chapter VI, Part A reg 2) which goes into effect on July 1 and mandates that all “packed containers” have verified gross mass weights reported to the carrier and terminal before loading.
While the rule is clear that the “Shipper” i.e. beneficial cargo owner or non-vessel-operating common carrier is responsible for verifying the weights, and it seems the U.S. Coast Guard will be the governing body, little else is certain.
First, to understand fundamentals of this regulation, we must look at the two acceptable methods for weighing containers. The first method is to use calibrated and verified scales that meet government requirements to weigh packed containers. The second method is weighing products to be shipped, including packaging, and then adding the “tare,” or the weight of the container, to determine the gross mass weight. Regardless of the method, the shipper must sign that the container weight is accurate.
As far as documentation to the carriers and the terminals, we have been told that the shipper is required to communicate verified weights in a shipping document. This communication to the carrier can be part of shipping instructions to the carrier or the weight can be communicated in a certificate per container that is submitted before loading the vessel.
Many of our export shippers, forwarders and NVOCC’s use electronic data interchange to send the carriers shipping instructions, whereby we identify the gross weight of the cargo when this data is transmitted. We do not include the tare weight, which is a new requirement.
As a result we are left with more questions than answers. For shippers using digital documentation, will there be a new template? What will the cost of additional paperwork be? Where are, and who operates, calibrated and state-approved scales? These are only a sampling of the numerous questions the new regulation raises.
The primary concern is that there is no standard process that carriers are using to implement this regulation. Many of us have received emails and alerts educating us that this rule is coming, but with no content on the procedure.
Our hope is that the industry will seek collaborative discussion and carriers will institute similar best practices for this regulation. The Agriculture Transportation Coalition and the Transpacific Stabilization Agreement have established a Container Weight Certification Compliance Committee to address critical questions on process, timing, programming and cost concerns. Mallory is also working with National Customs Brokers and Forwarders Association of America and Customs Electronic Systems Action Committee on this matter.
All industry stakeholders are encouraged to support these collaborative dialogues in an effort to get weight certification right; a repeat performance of congestion and chaos will just cost the shipping community more time and money.
The ultimate goal is to facilitate a supply chain of shippers, truckers, terminals and carriers that is not gridlocked because of this certification requirement. We need to work together to minimize the impact of delays and cost when this new requirement is mandated. The clock is ticking and July 1, 2016 is just around the corner.