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NVOCCs Request SOLAS Compliance Updates from IMO

NVOCCs Request SOLAS Compliance Updates from IMO

SOLAS is a top topic at the 16th TPM Annual Conference this week. The question is: Will shippers and NVOCCs be ready to comply with the new container weight verification which takes effect on July 01, 2016? What will be the consequences for non-compliance?

Yesterday, a working group made up of major non-vessel-operating common carriers, known as the THE Global Consolidators Working Group, is urging the International Maritime Organization to issue status updates of how the 162 contracting states to the SOLAS convention will implement the container weight mandate. The Global Consolidators Group said updates are needed because growing confusion and a well-established lack of information makes it nearly impossible for shippers and carriers to operate on a level playing field by following by the same standards. The Feb 28. letter to the IMO from the GCG Global Consolidators Working Group is the latest attempt by the industry to nail down regulatory expectations surrounding the amendment to the Safety of Life at Sea, or SOLAS, that takes effect July 1, 2016.

LETTER TO THE IMO - International Maritime Organization


THE Global Consolidators Working Group Representing the Leading Consolidators


February 28, 2016

International Maritime Organization
4 Albert Embankment
London SE1 7SR
United Kingdom

Re: SOLAS Container Weight Verification Requirements

The International Convention for the Safety of Life at Sea (SOLAS) has for generations been an historic and critical global instrument for the ocean shipping industry, helping to secure safe carriage of cargoes. The recent amendment, which was adopted by International Maritime Organization (IMO) Member States, requires (as of July 1, 2016) that a shipper verify the gross mass (Verified Gross Mass or VGM) of a container’s cargo/contents to the underlying carrier and terminal operator. While carriers, terminals and shippers alike will be affected by the new rules, the burden will primarily rest with shippers to provide the VGM.

The Global Consolidators Working Group (GCWG), comprised of the leading consolidator non-vessel-operating common carriers (or NVOCCs), supports the IMO’s initiative to enhance safety at sea—and on the waterfront. We understand the new amendment was drafted with the intent to further minimize accidents, both on the water and onshore. As shippers, we will be required to make significant changes to processes before July 1; as carriers (to our shipper-clients), we require clarity of how the new rule will be implemented and enforced. Uniform and consistent implementation across the globe is key to successfully implement IMO’s latest initiative. This will allow all parties to operate on a level playing field by abiding by the same standards—enforced in a similar way by all Member States.

As we approach July 1, many questions remain unanswered. Shippers around the world are currently unaware as to how IMO Member States will implement the SOLAS amendment, how the new requirements will be enforced, who will be enforcing them, the associated penalties and other relevant requirements. This lack of information, transparency and guidance makes it nearly impossible (and certainly impractical) for shippers to implement necessary arrangements to comply properly with the SOLAS amendment at the individual Member State level.

The IMO is best positioned to gather, compile and disseminate information from Member States regarding the VGM’s implementation status. We believe such a “status update” is critical to all members of the trade—carriers, terminals and shippers—as implementation day approaches. As a global industry, global clarity and standardization are needed.

Therefore, we respectfully request the IMO gather from each Member State the following vital information:

- Identity of the Competent Authority within each Member State that will implement and enforce the VGM requirement;

- Status of guidelines/regulations/rules that will be issued by the Member State to implement the VGM requirement;

- Whether a variance will be accepted by the Member State and, if so, what the variance will be;

- Whether the Member State will issue specific guidelines/requirements regarding timing and method of the VGM submission;

- Whether the Member State will provide a list of certified weighing locations/providers;

- What parties will be held accountable for violations of the VGM requirement and what the associated penalties will be; and

- Whether any Member State plans to delay implementation or phase-in enforcement of the VGM requirement.

In the interest of time, we request that this information be provided to all stakeholders, including shippers, carriers and terminal operators, no later than April 1, 2016. We thank the IMO for its consideration of this request and look forward to your response.

Gregory Howard, CEO
CaroTrans International, Inc.

John Abisch
Regional CEO - USA,
Caribbean & Central America
Ecu-Line N.V.

Klaus Jepsen, CEO
Shipco Transport Inc.

Charles Brennan
Executive Chairman
Vanguard Logistics Services
(USA), Inc.

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