As of 1 July 2016, the amendments to SOLAS regulation VI/2 regarding required evidence for the verification of the gross mass of packed containers entered into force as defined with IMO Circular Letter No. 3624, dated 10 February 2016. This Technical and Regulatory News provides key information on the VGM requirements to ensure smooth PSC inspections.
The responsibility of the verification of the gross mass as well as of its documentation and its communication to the ship lies with the shipper. However, the master of the ship is responsible for ensuring that only packed containers with VGM documentation are on board the ship.
In the following, you will find the main areas of the VGM requirements as defined in MCS.1/Circ.1475, dated 9 June 2014.
- Amendments are applicable for containers on any vessel to which SOLAS Chapter VI applies, with the following exceptions:
- Containers carried on ro-ro ships on short international voyages if these containers are only transported on/off the vessel on chassis or trailers (Annex, page 3, 3.2)
- Offshore containers that do not need to apply to the international Convention for Safe Containers (CSC) (Annex, page 3, 3.3)
- The shipper is responsible for recording the VGM in the shipping documents (Annex, page 1, 1.1; page 3, 4.1)
- The master has to take care that only containers with a defined VGM are stored on board (Annex, page 1, 1.1; page 3, 4.2; page 5, 8.1.1).
- There are two defined methods by which the VGM is to be obtained (Annex, page 4, 5ff)
Documentation and communication
- How the VGM is to be documented and communicated by the shipper is not defined; however, the following shall be observed (Annex, page 4, 6ff):
- Communication of the VGM within the shipping documents (Annex, page 3, 2.1.13; page 4, 6.1)
- The VGM declaration requires signature by the shipper or authorized representative of the shipper (electronic or name in capitals) (Annex, page 5, 6.2)
- Submission of VGM information in advance to ensure that the master and terminal representative use this information for the ship storage plan (Annex, page 5, 6.3); however, no duration is defined (Annex, page 5, 6.3.2)
- The shipping company is responsible for declaring a deadline by which the shipper has to deliver the VGM documentation in order to use the input for the preparation and implementation of the ship’s storage plan (Annex, page 5, 6.3.2).
- The shipping company should inform the port terminal facility whether the VGM has been received for each container and share the information provided by the shipper (Annex, page 5, 6.3ff).
Missing / exceeding VGM
- In case of missing VGM information, the master and the terminal representative may obtain the VGM on behalf of the shipper; however, procedures (including cost allocation) need to be agreed to between the parties involved (Annex, page 7, 13.1).
- Containers with a VGM exceeding the permitted gross mass as defined in CSC may not be loaded on board (Annex, page 6, 10.1).
With its circular MSC.1/Circ.1548, dated 23 May 2016, the IMO gives advice to administrations and Port State Control authorities on how to follow a practical and pragmatic approach for a three-month grace period ending 1 October 2016. Specifically, two topics are mentioned:
- Allowance for containers loaded before 1 July 2016 and which are transshipped on or after 1 July 2016 to their final port without VGM documentation
- Allowance for an implementation phase to improve procedures for documenting, handling and sharing VGM information
We recommend to have a copy of the MCS.1/Circ.1475 and MSC.1/Circ.1548 on board all ships. Furthermore, any problems or challenges should be openly discussed between shipping companies, shippers, port facilities and flag states in order to achieve a common approach as far as practical. It is advisable to review operational procedures and, where applicable, update these with respect to VGM topics, e.g.:
- When the VGM information is needed for the preparation of the storage plan
- Consideration of VGM in the loading computer software
- Transmitting or filing of VGM information
- How the master should handle containers with an overdue VGM declaration or when one does not exist
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The problem with mis-declaration, to give it a polite word, is that the shippers are so used to getting away with it that it has become the norm for many ports. Now we are dependant on the ports or whatever authority they use to correctly weight the containers, making sure of course that they are sealed before weighing. In some countries the flag states will pay as much regard to that as they do to UNCLOS. The only verifiable way is to fit the gantries hoist wire with a stressmeter that weighs accuratly to within a few kilos and wirelessly transmits the weight to both the shore loading computer and the ships computer thus other parties can verify the weight not just the port.It does seem ridiculous to be discussing weighbridges when far better and cheaper technology is already available and in use in many industries ashore. Could it be that maybe such a system would tell us more than the port would wish?
Next what penalties do we have in place for misdeclaration and the port not adequately having a proper VGM system in place. I suggest then that if the hoistwires in the discharge port are also fitted with these meters, then any mis-declared container be shipped back to the port of orign at the shippers expense.