With the SOLAS VGM deadline looming, more and more people are starting to get nervous about the whole issue in general and SOLAS VGM Method 2 in particular..
If you have been living underwater for the past few years and not aware of what SOLAS VGM Method 2 is all about, don’t worry, have a look at this article before you proceed further..
The questions I have been receiving from many readers in relation to Method 2 are :
- Will the 3rd party assessors VERIFY THE WEIGHT or VERIFY THE PROCESS OF WEIGHING
- Why must the shipper be accredited
- Can the packing station do the actual weighing or is the shipper expected to do it
- Should the shipper and packing station both be accredited
- If the shipper doesn’t want to be accredited since the packing warehouse is, can he still
be shown as the shipper on the BL
I discussed these questions about SOLAS VGM Method 2 and how it will work in South Africa, with Christopher John Walden of Supply Chain Compliance Services (SCCS), who are one of the 3rd party assessors in South Africa appointed by SAMSA..
Below is his guest post covering all above questions and more..
As a 3rd party assessor appointed by SAMSA,
What we verify
- We verify that the company that installed the scales/weighing device is accredited by SANAS
- We verify the system this company follows in weighing/packing and obtaining the VGM
- We verify that the weighing equipment/scale type used by this company is registered with NRCS
What we don’t verify
- We do not verify the weight of the cargo
- We do not verify the certification of the weighing equipment used, but we want to see the certificates used to confirm the accuracy of the weighing equipment
- We do not verify the calibration certificates, but we want to see the certificates to confirm the accuracy of the weighing
- We do not verify the certificate of the person doing the calibration, but we want to see the certificate to confirm the accuracy of the calibration
Who needs to be accredited – the shipper or packer or both..??
The shipper definitely needs to be accredited because they are the responsible party as per the SOLAS convention to ensure that the weight of the container is declared correctly.
Although some of the packers are also accredited, as the name implies, the “packer” is simply that. They are there to pack the cargo into the container.
But the packer also has a responsibility in this chain and needs to
- make sure that the weights of all the cargo, dunnage, pallets, strapping and any other packing/securing materials are entered onto a packing list or some other form of document
- add the total weight of the cargo and packing material inside the container to the TARE weight of the container to calculate the VGM.
If the packer is a third party, there needs to be an agreement in writing between the shipper and the packer to cover above.
If the shipper packs their own product, they are both the shipper and the packer and are therefore responsible to calculate the VGM and update same in the port system (NAVIS) for export of containers.
Regarding the question about the shipper not wanting to be accredited but still appear on the BL, because the packer is accredited — My answer would be NO, it is not possible.
The packer could possibly be a groupage shipper and accredited in his own right as his name would appear on the Master bill. But if you want to be on the bill as the shipper you need to be accredited.
Is the Shipper accreditation a lengthy process..??
Accreditation of this shipper need not be a lengthy procedure as many fear.
- Firstly we look for the agreement between the shipper and the packer
- We then take the packers accreditation number into account and do a physical check of their procedures like
- whether they include that particular cargo type
- or a physical check on the weighing equipment and
- look at the training records
If a packer has already been accredited , we cannot just take this accreditation and simply offer a new shipper his accreditation. We need to still look at the packer’s procedures and verify that these procedures are suitable for the cargo the new shipper requires.
There can also be an agreement between the shipper and the packer , whereby the packer would be the name on the BL, (this does happen) and they have an internal agreement in place covering the legal side of this arrangement.
As a SAMSA accredited third party we check
- compliance to the SAMSA mandate (Marine Notice 25 of 2016)
- traceability, responsibility and a verifiable paper trail to show how the VGM is achieved
- proof that the staff who are involved in the process are competent in the position they hold
- this needs to be proved by records that show the training, toolbox talks, one on one instructions
- all of which may possibly have been done verbally but needs to be backed up with a signature of the staff showing understanding
- the actual packing of the container to verify that the procedure documented is the same as the actual method used and the CTU code of practice is being followed
Load planning which is so often missing is an integral part of making sure that your container
- is balanced,
- has a low center of gravity,
- is packed safely so as to minimise any shifting of cargo and
- there is no danger to persons receiving the cargo.
The aim is to lift the level of competency in the entire supply chain and hopefully we are all helping to reduce the accidents that plague our road, rail and shipping industry.