In a rare showing of solidarity among normally fierce competitors, the letter was signed by Gregory Howard, CEO of CaroTrans International, Inc.; John Abisch, Regional CEO – USA, Caribbean & Central America, Ecu-Line N.V.; Klaus Jepsen, CEO, Shipco Transport Inc.; and Charles Brennan, executive chairman, Vanguard Logistics Services (USA), Inc.
The new regulations, due to take effect July 1, 2016, require shippers to declare the verified gross mass (VGM) of laden containers prior to being loaded on to a ship. But beneficial cargo owners have been complaining rather loudly that the SOLAS amendment does not include any language regarding how the rules are to be implemented.
As a result, the industry has been left wondering how individual IMO member nations will enforce the VGM requirement, something that is likely to vary greatly from country to country.
In fact, a majority of shipping experts interviewed by American Shipper on the subject said the fact that individual countries will be responsible for enforcement has created widespread uncertainty and could potentially make the issue even more complex as time goes on (See the American Shipper March cover story, “The Weight of Uncertainty,” pages 20-25, for more).
GCWG in its letter to the IMO noted that although “carriers, terminals and shippers alike will be affected by the new rules, the burden will primarily rest with shippers to provide the VGM.”
The NVOCC group asked the IMO to address how member states will implement the SOLAS amendment, how the new requirements will be enforced, what group will be responsible for enforcing them, associated penalties and other relevant requirements.
“The IMO is best positioned to gather, compile and disseminate information from Member States regarding the VGM’s implementation status,” GCWG said. “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.
“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,” it added.
Specifically, the group requested the IMO gather the following information from each member state:
• 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.
The Global Consolidators Working Group asked the IMO to provide the requested information to all industry stakeholders no later than April 1, 2016 in order to prepare for the July 1 implementation date.
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