FILLING IN THE GRID FOR SOLAS IMPLEMENTATION

National authorities
Over the last month, more and more information is being released by national authorities on how they are planning to implement the SOLAS regulation. As expected, national variations are emerging, for example around tolerances and penalties for non-compliance.

In order to keep track of the latest status, the World Shipping Council updates the latest announcements on a country by country basis on their webpage. At least as important as national implementation of the SOLAS amendments will be the decisions taken by carriers and terminal operators around both physical and information issues.

Information and communication
Carriers have also begun to release how and when they wish to receive Verified Gross Mass (VGM) data: as a separate information flow or as part of the shipping instructions. There is a general agreement that a cut-off time at the point of booking is too early. Solutions announced range from aligning with the CY cut-off time at latest, to simply advancing all cut-offs by one day from present practice. In order to start preparation and be ready by the 1st July, Damco works with certain assumptions, such as:

• It is the responsibility of the shipper to provide the VGM to the carrier, and it is the shipper’s responsibility to communicate with the terminal.
• Within our internal IT systems, the new VGM-related fields are kept separate from existing data elements such as those related to customs declaration.
• The VGM will not be on the Master Bill of Lading (MBL), consequently the documentation provided by the carrier will not change due to SOLAS.
• Carriers will give a confirmation if they’ve received the VGM data, but not verify if the VGM data provided is valid. However, this working assumption might need to be reviewed due to recent announcement by the US Coast Guard that it is up to the Carrier to enforce SOLAS regulation.

Many parts of the carrier community are now working actively together to standardize an EDI solution for communicating VGM. Some carriers are also working on web-based approaches so it is safe to assume there will be multiple ways of achieving the same result.

Weighbridges and waybills
The physical and commercial approaches that carriers and terminal operators will adopt are beginning to be revealed slowly – we know from our own efforts that the absence of an announcement doesn’t mean there isn’t a lot going on!

Terminal operators at different parts of the word, have announced that they will be offering weighing as a commercial service. The physical implications are not trivial, and it is proper that terminal operators should take time to get them right. There is insufficient weighing capacity at many terminals, and introducing VGM is not just a matter of buying a weighing machine: it introduces new processes that have to be accommodated, increased demands for space and may in some cases require the whole flow of containers from gate to quay to be reconfigured.

In order for the shipper to be ready by 1 July 2016, it should also explore alternatives to weigh cargo away from the terminal, at their own premises, consolidation centres or elsewhere. Damco is currently investigating where it will be able to offer physical weighing, either at our own facilities or via 3rd party providers.

Commerce and contracts
A variety of commercial options and pricing ranges are currently being developed. A likely shape is that CY traffic, weighed as a stuffed container (SOLAS Method 1) will attract a fee per container; for CFS where the cargo is weighed and the tare weight added (Method 2), a price could be per item weighed. It is possible to also have Damco support with the data transmission / filing.

Depending on local circumstances, VGM charges will vary. Damco expects to publish its commercial options in April and will offer customers the most appropriate route to compliance. Pricing may be heavily dependent on local factors, such as availability and local regulation. We are confident that if all the parties continue to work together as they have been doing, the SOLAS regulations will be introduced and enforced world-wide by the deadline.

Continuing the conversation
We invite readers to ask questions or share updates on how your preferred carrier or country is progressing on the SOLAS implementing by leaving your feedback in the comments section below.

Damco will soon be organizing a live webinar “Introduction to the new SOLAS regulations: everything you need to know” on 17 March. You can register for this webinar here. For more background you can also have a look at our previous blogs.