Safety of Life at Sea (SOLAS)

May 24, 2016

The International Convention for the Safety of Life at Sea (“SOLAS”) sets minimum standards for the construction, equipment and operation of ships to ensure the safety of vessel operations.

SOLAS Chapter VI addresses carriage of cargo and includes specific requirements related to the safe stowage and securing of cargo. Chapter VI, Regulation 2 currently requires shippers to confirm the gross mass of cargo in writing in appropriate shipping documents prior to loading the cargo on a ship. Due to problems related to incorrect declarations of container weights, the amendment to Regulation 2 supplements the requirement to provide the gross mass of cargo by implementing specified procedures by which container gross mass must be verified. The resulting Verified Gross Mass (“VGM”) must be stated in the shipping document, signed by the shipper, and provided to the master and terminal in advance. If the VGM is not provided to the master and terminal, the container may not be loaded on the ship.

Thus, the amendment includes two requirements: (1) the “shipper” must ascertain and provide the VGM for each container, and (2) the vessel is prohibited from loading containers for which VGMs have not been supplied. In terms of enforcement actions in the United States, the Coast Guard takes the position that SOLAS and the International Safety Management (“ISM”) Code place the ultimate responsibility for the safety of the vessel on the owner of the vessel and the master, and not the shipper. Thus, enforcement action would likely be taken against the vessel owner/operator for failing to meet this new requirement if a container was loaded aboard one of its vessels that does not have a VGM.

TRAILER BRIDGE REQUIREMENTS

SOLAS does “NOT” apply to non-self-propelled barges, under SOLAS Chapter VI provisions “Carriage of Cargo”, therefore this does not apply to cargo shipped with Trailer Bridge as all marine equipment is non-self-propelled barges.

We take this opportunity to underline the importance and the responsibility of properly and accurately providing cargo weight on all shipping documents as per current DOT and Maritime regulations. The safety of our crew, the assets, and your cargo at sea remains a critical focus for Trailer Bridge.