Date: 10/06/2013 – Source: TT Talk 175 – There is general consensus that the inaccuracy of weight declaration in the unit load industry compromises safety and efficiency. There is rather less agreement on how to implement changes that are appropriate and proportionate. TT Club is hosting a Round Table at the forthcoming TOC Europe Conference to allow the debate to continue.
That the true weight of a high percentage of the 130 million TEU shipped around the world last year was not accurately known is in little doubt. What remains a matter of debate is the extent of these inaccuracies, the consequences regarding safety and dangerous incidents, and how regulations can be imposed to redress the situation.
The TT Club has been active in this debate for many years and will continue in this role by providing the moderator for a Round Table discussion on the subject at the up-coming TOC Europe Conference in Rotterdam at the end of June.
The case for change
A systematic post-incident verification of the weights of packed containers on a particular ship is rarely possible, but two incidents in recent years have provided such an opportunity. When ‘MSC Napoli’ ran aground off the UK south coast in January 2007, 137 out of the 600 containers it was carrying on deck were found to be at least three tonnes heavier or lighter than had been declared on the ship’s manifest. In June 2011 in Algeciras (Spain) the capsizing of ‘Deneb’ during unloading revealed that a higher percentage of boxes – 64 out of 150 – were not laden as originally declared.
‘The tendency is to assume that the weight given at the time of booking (submitted by the shipper to the carrier) is the actual weight’
At a recent industry seminar Richard Marks, director of the International Cargo Handling Coordination Association (ICHCA), drew conclusions from these statistics. ‘The tendency is to assume that the weight given at the time of booking (submitted by the shipper to the carrier) is the actual weight – this must account for a large proportion of misdeclarations’, he said. The degree of ‘variation’ – the error ratios of 22% in the case of ‘MSC Napoli’ and 42% for ‘Deneb’ – is unsurprising for many in the industry. The more important question is what the industry will do about it.
Some shipper representatives would like to be more certain about the degree to which overweight containers compromise safety. Do they consistently cause incidents such as container stack collapse, road and terminal vehicle overturning, crane failure and ship capsizing? In a recent high-profile article Chris Welsh, the Secretary General of the Global Shippers Forum pointed out the lack of evidence linking an estimated 8, 000 safety-related incidents involving containers per year to overweight issues. ‘Few, if any of the incidents revealed that misdeclaration was the cause of the incident’, he wrote. ‘But in some instances it was likely to have been a contributory factor’, Welsh conceded.
Few in the industry deny that there is a genuine problem concerning the misdeclaration of container weights; the problem is more agreeing on how accuracy can be achieved, under whose responsibility and what degree of regulation is required to make the provision of such information sufficiently universal.
‘packed freight containers should not be loaded on board a ship without a ‘verified gross mass’
The next IMO DSC meeting will consider this amendment in September this year and may adopt it by December 2014, leading to earliest entry into force in July 2016. However, the detail continues to be hotly debated. The means by which weight verification should be achieved has been extensively considered by a correspondence group of IMO members, which was tasked with confirming the necessary amendments to SOLAS along with comprehensive guidelines. The guidelines will hopefully resolve how the revised regulations can be enforced in every containerised situation, including the least sophisticated operations. The deadline for final the correspondence group submissions is imminent, after which other interested parties can provide briefer comments to be considered in the debate in September.
What then is the best way to ensure an accurate ‘verified gross mass’ for each container? Shippers, as represented by the European Shippers Council (ESC), favour the so-called ‘German compromise’ put forward at DSC 17, which offers ‘weighing by calculation’ as the solution. This relies on an improved, more reliable version of the current process whereby those responsible for packing calculate the mass of each item of cargo loaded into the container, plus the mass of pallets, dunnage and other securing material, in order to reach the sum of these values to provide a total mass of what is packed. When added to the known tare mass of the empty container this would produce an accurate ‘gross mass’ of the packed unit.
‘What then is the best way to ensure an accurate ‘verified gross mass’ for each container?’
The ESC claims that the introduction of a ‘mandatory deadline for delivery of final shipping instructions’ would be sufficient to solve the misdeclaration issue. The proposal for 24 hour advance information would allow shippers sufficient time after the container has been packed and dispatched to inform the carrier of an accurate weight. However, the carrier organisations, the World Shipping Council (WSC) and the International Chamber of Shipping (ICS), representing ship owners and operators, disagree. SOLAS already requires the shipper’s declaration (of gross mass) to be ‘sufficiently in advance’ to allow effective stowage planning – as well as to be accurate. The WSC has consistently argued that the cut-off for stowage planning is impacted by many factors, while recognising that advance cargo information is required 24 hours before loading at the point of export for many destination countries.
While there may be some communication challenges to ensure that updated shipper declarations are used in the final ship planning process, accuracy is the key issue. As ICS’s John Stawpert succinctly stated, ‘Faulty data remain faulty irrespective of when they are delivered.’
The broader context
So the debate over weighing goes on. But, while preparing for the discussions on the weighing of containers at TOC in Rotterdam, the TT Club is also mindful that this is a small part of a broader safety context. The safe packing of cargo in containers, which is the subject of another TOC Round Table, is arguably more critical in avoiding container related incidents.
Bill Brassington, the appointed consultant developing the ILO/IMO/UNECE Code for Packing Cargo Transport Units, has drawn attention to the ILO’s study, which suggested it was not weight, but inappropriately packed and secured cargo that caused most problems. It is vital that this issue of safe cargo packing be given as much attention as that of accurate cargo weights.
This level of consensus brought the debate as far as the IMO, which, at the 17th Session of its Dangerous Goods, Solid Cargoes and Containers Sub-committee (DSC 17) in September 2012, was unable to finalise the detailed changes to international law relating to the verification of container weights. However, a recommendation was made to amend SOLAS (the International Convention for the Safety of Life at Sea) to require that packed freight containers should not be loaded on board a ship without a ‘verified gross mass’.