SOLAS VGM from 1 July 2016: packing and securing materials count

From 1 July 2016, a packed container may not be loaded onto a ship covered by SOLAS chapter VI unless the master and the terminal have its verified gross mass, or VGM, in time for the stowage plan. The amendment to SOLAS regulation VI/2 was adopted in November 2014; the IMO guidelines in MSC.1/Circ.1475 explain how it is meant to work.

Much of the preparation for the rule concerns weighing equipment and data exchange. For anyone who packs export crates, pallets and container loads, there is a more immediate detail: the mass that must be verified includes everything used to pack and secure the cargo.

What the rule asks of the shipper

The guidelines place the responsibility on the shipper, meaning the party named on the bill of lading or sea waybill, or the party that contracted the carriage. The shipper must obtain the verified gross mass and communicate it in a shipping document, clearly identified as the verified gross mass and signed by an authorised person.

Two methods are allowed:

• Method 1. Weigh the packed and sealed container, or have a third party do it.
• Method 2. Weigh all packages and cargo items, including pallets, dunnage and other packing and securing material, and add the container’s tare mass. The weighing method is subject to approval by the competent authority of the State where packing was completed.

SOLAS sets no fixed deadline, other than that the figure must arrive in time to be used in the ship’s stowage plan. The guidelines leave it to the carrier to tell the shipper its cut-off. In the UK, the Maritime and Coastguard Agency’s MGN 534, published in June 2015, sets out national guidance, including an application process for shippers who want to use Method 2.

Packing and securing materials are part of the mass

The guidelines define gross mass as the container’s tare plus all packages and cargo items, “including pallets, dunnage and other packing material and securing materials”. Securing material is defined as the dunnage, lashing and other equipment used to block, brace and secure cargo in the container.

In practice, that means:

Item packed into the container	Included in VGM?	How a packer can capture it
Product and its retail or transport packaging	Yes	Weighed package or accurate marked mass
Pallets, skids and crates	Yes	Weigh the finished unit, or record the tare of each type
Dunnage, bracing timber and void fillers	Yes	Weigh as loaded, or use a recorded mass per piece
Strap, buckles, seals and lashings inside the container	Yes	Weigh strapped units after strapping; record extra lashing material
Loose spare consumables shipped in the container	Yes, as cargo	Weigh the cartons like any other package

Individual strap and buckle masses are small, but they are not zero, and on a container of many strapped units they add up with the timber. The simplest approach under Method 2 is to weigh each unit after it has been strapped and labelled, so packing and securing material is already included. Original sealed packages that carry an accurate, permanent mass marking do not need to be weighed again.

Method 2 is not suitable for everything. The guidelines say that items such as scrap metal or bulk cargo, which cannot practically be weighed individually, should use Method 1.

A transition, not a postponement

At its May 2016 session, the IMO Maritime Safety Committee agreed advice in MSC.1/Circ.1548. As the IMO briefing of 23 May 2016 explains, administrations and port State control authorities are encouraged to take a “practical and pragmatic approach” for three months after 1 July 2016. The aim is to let containers loaded before 1 July but transhipped afterwards reach their destination, and to allow time to refine electronic data exchange.

The committee was clear that there should be no delay in implementing the requirement itself. Shippers who plan for the July start avoid having to explain themselves at the terminal gate.

A checklist for packers before 1 July 2016

• Name the shipper. Confirm who appears on the transport document and who will sign the VGM declaration.
• Choose the method. Method 1 needs access to suitable weighing equipment; Method 2 needs every item weighed and a weighing method approved by the competent authority of the State where the container is packed, which in the UK means the MCA.
• Weigh units after strapping. Build the weighing step into the packing sequence so crates and pallets are weighed complete.
• Record tare values. Keep a list of recurring packing materials such as crate types and standard pallets, with their measured mass.
• Check the container plate. A container may not be loaded if its gross mass exceeds the maximum shown on its safety approval plate.
• Ask for the cut-off. Each carrier will set its own deadline for receiving the VGM.
• Keep the records. Store weighing records with the booking so discrepancies can be traced.

Keeping packing data consistent

Packing specifications that already list strap type, buckle size and the number of straps per unit make Method 2 easier, because the securing material for each unit is predictable. If you are reviewing woven strap, galvanized wire buckles or steel strapping seals for export packing, include the unit count and packing quantities in your enquiry through the contact page, so component data can sit alongside your weighing records.