Solas and MO42 regulations; Our operational procedures and charges.

Home » Solas and MO42 regulations; Our operational procedures and charges.

WE WILL NOT  BE CHARGING YOU TO WEIGH ALL YOUR LCL CARGO.
( because we will only weigh a shipment if you request us to do so and charge you as below )

WE WILL ONLY CHARGE A MINIMAL PER SHIPMENT FEE ( on all shipments as per below )

the below message explains the whys and wherefores, I suggest you take a moment to read this;
VGM COMPLIANCE CHARGES AS APPLICABLE FOR LCL CARGO

We are sure you are already very familiar with the changes in SOLAS (Safety of Life At Sea) regulations which will need to be implemented for departures on or after 22nd June 2016.
In short, the new regulation provides for a mandatory provision of a verified gross mass (VGM) – of all export containers.
In preparation for the changes in these regulations we were the first to propose a Draft method of operation to the market on the 30th of May;  We asked for your input and feedback as to the ability of your customers to provide you with a weight that you would be prepared to present to us, under your letterhead, as being totally accurate.This would then allow us to use this weight to create our aggregate manifest weight and declare under law a VGM on our Ocean B/L using Method 2.

After a lot of feedback from forwarders and further discussions with AMSA we have now adjusted this to a “final” operational method as below

Firstly, it is important to be clear on the fact that the verified gross mass (VGM) as outlined by regulations, pertains only to the weight of the container (This obviously includes the shipments contained therein as well as all dunnage materials and the container tare) this then implies that under law there is no such thing as a “ VGM ” for an LCL shipment. As said already, the responsibility for the accuracy of a containers VGM lies with the shipper on the Ocean B/L.

So in the FAK/LCL environment, and given that EIFC is the shipper of record on the Master Bill of Lading, that responsibility lies with us.

This means that our Melbourne, Sydney and Brisbane Tradelane Supervisors at Evans International Freight Consolidators will submit the VGM under their name ( on behalf of the company ) and assume responsibility under this declaration.

They will request you to provide us an accurate weight ( by way of wording on our Booking Confirmation ) and assume that the weight of any given LCL shipment, as submitted to us by you, on behalf of your customer, is true and accurate.  This will need to be submitted to us no later than the advertised LCL Cutoff date ( in order not to bring closeoff’s forward your Forwarding Instruction will need to be presented to us no later than the advertised cutoff ).

We will NOT be asking for a specific Weight Declaration document to be submitted certifying the weight of a specific shipment.  We will accept the weight information via the same method we do today – i.e., as part of tbooking from you and then on the FI.

Should you not be able to provide us with a weight that you are stating to be an accurate gross mass of your booked consignment(s) you will request us to weigh the cargo and a weighing charge as below will be levied.

In conjunction with SOLAS implementation our Terms and Conditions of Trade have been amended ( as proposed by the Forwarding Industry Peak Body: A.F.I.F. ) and these will be sent to you on a separate email.

No doubt you will have already had extensive communication with your customers on this subject, but we urge you to ensure that they are aware of the need to inform you of precise and accurate weight details for their cargo. We recommend that Exporters conduct internal testing to establish that the known weight of their products is in fact accurate.  It important to remember and ensure that the weight includes all packing materials – including pallets, skids etc etc.  The responsibility of providing an accurate and precise weight of the cargo falls on your customer and therefore, in turn, on you ( weights provided to you should, in most cases, have been obtained using an NMI approved and calibrated weighing device ).

For the sake of due process, we will be performing spot checks on individual shipments upon receipt at our CFS’s at our cost.  Additionally our CFS operators nationally will charge us to weigh the loaded Containers to ensure our compliance.

In deciding on how to comply with MO42, our goal was to meet the commercial needs of our Freight Forwarder clients and still to comply with the legal requirements of the order which has now been enacted into Australian Federal Law.

In deciding on our proposed method, we found challenges at almost every step of the consolidation process and whilst no one else has yet mentioned it, we also had to take into account the implications to the devanning agent at any Destination or transshipment point ( Hub Port agents will have to be able to rely on our HBL weight for calculating their Export Containers VGM’s.)

We also strongly believe there must be a data match on our Manifest when compared to the Ocean B/L ( and PRA ) …………… even if only to ensure there are no delays incurred on arrival with destination Customs Regulations.

This has brought to light many anomalies on the way FAK/Consolidation cargo is handled across our 3 weekly load ports in Australia and we believe the processes and outcomes thereof are somewhat of a moving target until AMSA’s audit process has been put to the test.

And so we will be implementing the following modest charges (effective 22nd June 2016)

LCL
SOLAS Admin fee: A$ 20.00 plus GST per Master HBL (on all cargo)

Optional SOLAS Weighing fee: A$ 6.50 w/m, min. A$30.00 plus GST per individual check in line (fee applied only if you request us to weigh a specific shipment)

On a personal note, I would have preferred that all the consolidators brainstormed together and came up with an industry SOP but for many reasons this has not happened.

I believe the process and charges as outlined above are the least intrusive and most cost effective way to manage MO42 in an LCL environment without penalizing professional shippers by way of a mandatory weighing cost and still recovering our additional outgoings as will be levied by the CFS’s across the country.