It is extremely worrying when I stand on quaysides around Europe and at ship’s side rails in the most prominent of UK container ports and I not only hear but also see a huge lack of understanding of our global container industry. This saga, potentially an epidemic, came to light in early 2014 when the new CTU code of practice was first put to the ILO and IMO for recognition and approval. Here lies the problem; how many of our cargo surveyors actually knew this was happening in 2014 and more so; how many are aware of the content of the new code and how it affects container transport today? The answer? A disappointing few. In 2016 alone I have emailed the ‘new’ CTU code to over twenty different surveyors (albeit not all IIMS members but some readers may now feel a twinge of recognition) who did not even know the ‘new’ code existed when we were discussing packaging related issues on the quay.
The original blue book guidelines for the packing of cargo transport units were published in 1997 and provided a set of practical measures for ensuring the safe packing of cargo in container, road vehicles and railway wagons. This applied to all operations throughout the entire intermodal transport chain but was only intended as a set of guidelines and as such was not mandatory. For those budding cargo surveyors who have actually read the blue book (I doubt that the number of readers that have a copy within their grasp gets to double figures) you will be aware of its limitations with regard to the types of commodity shipped and the methods available. Times have changed and technological developments now need to be taken into account. The new code of practice was initially intended as a non-mandatory publication to form the basis for national legislation currently recognised and being prepared for by 163 countries. Effectively this has become one step below a mandatory UN regulation, which is effectively what the international industry needs – that is a kick in the steel box backside in an effort to raise standards across the board. Here’s the next problem; despite the courageous work of our friends at ICHCA (the International Cargo Handling Coordination Association) very few industry members (and that includes surveyors) actually know about it, let alone the content and the implications. The importance of such legislation only comes to light when something goes wrong and that is the problem and, historically has been. After all, we’ve all heard it before; ‘that’s the way we’ve always done it’. Well not anymore on my watch!
The new CTU code is from the outset a vast improvement on the original guidelines and it is divided int o the following chapters for consideration:
3. Key requirements.
4. Chains of responsibility.
5. Transport conditions.
6. CTU properties.
7. CTU suitability.
8. Arrival; checking and positioning of CTUs.
9. Packing cargo in CTUs.
10. Additional advice (relevant to specific cargo).
11. Actions on completion of packing.
12. Advice for receipt and unpacking.
13. Training on packing.
Relevant supporting annexes show a vast improvement for educational purposes and cover related areas such as manual handling, lashing guidelines, working at height, packing and securing calculations, friction considerations, load distribution and practical inclination tests. Phew! It’s a lot if you don’t know the basics but already the introduction of the code has seen a rapid improvement in packing and securing quality of the hundreds of containers our office has inspected in the last eighteen months.
So, is the CTU code a book you need to learn? Of course! But it could never be that easy; it does, has already and will continue to change as various updates are introduced, just to keep you on your toes. Who reading this has heard of MGN534 from the MCA? The UK’s version of just one section of reference entitled ‘CARGO SAFETY - Guidance on the implementation of the SOLAS VI Regulation 2 amendment requiring the verification of the gross mass of packed containers.’ It’s all there and the various regulations interlink in a rather annoying way. Especially when updates and amendments are sporadic. Alas! Section 4.2.3 of the CTU code – the Packer’s responsibility (and yes there’s a bit in there for every party) shifts the whole requirement for container weighing to those that pack it rather than handle it. The CTU code states that “The gross mass of the CTU needs to be verified before any transport operation commences. Incorrect gross masses are a hazard for any mode of transport, especially container ships where stack weights are critical. Therefore, the gross mass verification should be carried out before the unit leaves the premises of the packer. If a certain transport mode deems it necessary that a re-verification has to take place when the CTU is transferred from one mode to another, this is beyond the scope of this Code and may be regulated in the regulations of that mode. Where a cargo is to be transported by road or rail only, the packer need only provide the mass of the cargo and any packing and securing material to the carrier when the tare of the transport vehicle is not known.” Section 4.2.12 then states that all parties are now responsible for the provision of the VGM (verified gross mass) of the container in addition to all the other information along with the container number, seal number and contents. Now, many will say that container weights have always been stipulated on bills of lading but how accurate are these? From our own survey inspections at the ports of Felixstowe, Tilbury, DP World London Gateway, DP World Southampton in the UK alone I can confirm; not very.
So let’s look at this in basic principles, courtesy of our friends at OOCL and DP World we can lay the generic terms out as below:
What is VGM?
VGM is the total gross mass of a packed container, which includes the cargo weight, block & bracing materials and container tare. The SOLAS Convention offers two methods to obtain the VGM:
Method No. 1 - Weighing the packed container using calibrated and certified weighing equipment.
Method No. 2 – Calculating the sum of the single masses = Mass of cargo items + all packages (pallets, dunnage, securing material packed in the container) + container tare weight as certified and approved by the national authorized body.
1. It is inappropriate and impractical to adopt Method No. 2 for scrap metal, un-bagged grain and other cargo in bulk.
2. If a container with a gross mass exceeding its maximum permitted limit (the maximum payload) as indicated on the Safety Approval Plate under the International Convention for Safe Containers (CSC), the container will NOT be loaded onto a ship even with the proper VGM documentation.
Who is responsible for VGM?
The responsibility for obtaining and documenting the VGM of a packed container lies with the shipper shown on the Ocean Carrier Bill of Lading. The shipper is responsible to provide the VGM to the ocean carrier and/or port terminal in order to meet the SOLAS and local regulatory requirements and/or specific port terminal procedures where applicable.
When did VGM come into force?
The new SOLAS requirements were effective on the 1st July 2016.
The shipper must ensure that the VGM is provided sufficiently in advance for use by the Vessel’s Master and the terminal representative towards the ship stowage plan.
The VGM cut off time should be advised in the form of a Booking Confirmation once available though it is anticipated that the VGM cut off times will vary from one country/port to another.
So, with the mandatory requirement of VGM now in force who was ready for it? Shipping lines and container terminals across the world have been promoting the prospect of mandatory container weighing with the focus being on shippers to ensure that they have a VGM for any laden export containers that they are shipping out of the UK with a clear message; If a VGM is not provided then the container will not be loaded. Many container terminals have looked to assist in the process (in return for a nominal fee of course) and set up their own VGM provision which is usually done in one of a few ways; this being by weighbridge, reach stacker verification, straddle carrier load cell or gantry crane weight cell during the various stages of handling. All weighing systems must be certified for the task and in order for the container terminal to assist in the process the container needs to arrive on site for weighing well in advance of the vessels arrival time. DP World and Hutchinson ports in the UK insist on VGM declaration a minimum of twenty-four hours before vessel arrival or the container will be cut from the load plan. For those eager shippers with their own certified weighing system a VGM declaration can be made well in advance.
This all sounds like a well establish system, perhaps even well oiled. But is it? The TT Club published a seminar update following ICHCAs annual conference in Antwerp in early June stating that with the original deadline of 1st July 2016 for VGM conformance globally, less than 15% of the 162 IMO member states in which VGM regulations will be mandatory had actually issued any form of guidance in procedure, implementation and enforcement. The summary of a Maritime Safety Committee Meeting with ICHCA in June recognised that VGM would need to be considered as part of not only SOLAS rules but also the ISM Code, IMDG Code and our beloved CTU code and this alone could see updates to the various codes of practice which affect all our work in this ever technical industry sector.
Following on from this we have reviewed the physical implementation of the new rules looking at how both shippers and handlers react to situations that are expected to arise. One example viewed only last week in the London Container Terminal (Tilbury) concerned a single TEU of particularly high value. Due to its special nature the container was delivered by road transport directly to ship with Police escort, private security and budding surveyors in tow. On lifting by gantry crane from trailer to ship an interesting message flagged up on the planners system that the weight was not in accordance with the VGM declaration made twenty-four hours previous. The container was rejected from the carrier leaving its fan club on the quayside feeling somewhat useless. Determined to prove our worth we banged on the planners desk until they would reconsider and pushed the terminal to re-measure the containers weight. Interestingly by straddle carrier the weight was the same as per declaration but by crane it was slightly heavier despite both units being calibrated and certified for the task. After several minutes of finger pointing we achieved our aim and the dejected planners succumbed and allowed the container to load. Gold star for us, though where does this leave the validity of the VGM system when two approved methods of weighing result in different outcomes? The answer is a more regulated, expensive system with margin for error, despite our best attempts to be rid of it. The margin may be small we agree but on an 18,000 TEU carrier is even a 50kg margin of error in every container acceptable?
The VGM system is we agree critical is improving safety on board our container vessels. Historically guesswork and assumptions accompanied by poorly completed bills of lading were the tools for planning stack weights and hold distributions. When we still can’t get it 100% right 100% of the time it is easy to understand why stack collapses occur and vessels are place in jeopardy, the efforts of the combined parties worldwide should assist in the reduction of such. This is potentially yet another case of hurry up and wait to see what the impact will be. However aside from the negatives of additional paperwork and costs the real outcomes will be positive and the enforcement and promotion of the safety of our ships and those who work on and around them. This is where we can all play a part.
Within the surveying world the understanding and awareness of the new code needs to be increased at a higher level and hopefully the modifications currently underway to the IIMS Container Surveying self-study module and potential practical course to accompany this will lay the foundations to this opportunity.
Director, Sterling Global Marine Limited
• Implementing Guidelines issued by IMO's Maritime Safety Committee.
• Guidelines for Improving Safety and Implementing the SOLAS Container Weight Verification Requirements by World Shipping Council (WSC)
• IMO ILO UNECE Guidelines for the packing of cargo containers 1997.
• IMO ILO UNECE Code of Practice for the packing of transport units 2014.
• ICHCA seminar reports, June 2016.
• DP World Southampton VGM information database.
• OOCL Shipping, VGM information database.
• MGN 534.