FAQ - establishing the verified weight of packed containers


Is the weight required to be certified?

Depending on whether the weight concerned is manual or automatic, it must meet the requirements for accuracy that have been stipulated in the executive orders hereon issued by the Danish Safety Technology Authority. The weight is not required to be certified, but the manufacturer of the weight must guarantee that it meets the preconditions determined. Similarly, the manufacturer of the weight must ensure on an ongoing basis that its accuracy is maintained (calibration of the weight).

We do not use an ISO 9001 quality management system, but another quality management system. How can we find out whether it is equal to that required?

The condition for using method 2 (the calculation method) is that the shipper is operating in accordance with an ISO 9001 or similar quality management system, including that the procedures described in order no. 397 from 2016 have been incorporated and verified by the accredited body. Companies that have been AEO certified within safety and security (AEOS or AEOF certification) are also presumed to be able to determine and maintain the procedures needed.

In case it is not an ISO 9001 quality management system, the shipper must ensure that the quality management system used is equal to an ISO 9001 system, including that it is a managed, documented, verifiable quality management system that has been approved by and is being controlled by an audit body accredited in the EU on an ongoing basis. The shipper can ensure this by contacting the associated accredited body, respectively by contacting an accredited body that has been recognised for performing audits of management systems in accordance with ISO 19011:2012. An overview of Danish ISO 9001 accredited companies is available from the webpage of DANAK.

Is an approval of an ISO 9001 quality management system or similar required to be approved by the Danish Maritime Authority?

No, the accredited body approves the quality management system, including the procedures that are used to establish the verified weight in accordance with method 2. It must be possible to present the approval to the Danish Maritime Authority, if and when needed.

When can the company start to use method 2?

As soon as the accredited body has vouched for the company's quality management system and the procedures incorporated in connection with the establishment of the verified weight, the company can use method 2. If the quality management system enables the company to determine, incorporate and verify the new procedures on the establishment of the VGM on its own, the company can start using method 2 when the procedures have been incorporated.

Must the carrier be informed about the method used to establish the verified weight?

No, the shipper is required to inform only the master or his representative as well as the terminal operator about the verified weight. However, the shipper must be able to document to the Danish Maritime Authority which method has been used in connection with the indication of the VGM (Verified Gross Mass) for each individual container.

The regulations require the shipper to confirm the verified weight through his signature. Does this mean that a "physical signature" must accompany the VGM statement?

According to Danish regulations, an electronic signature is sufficient. However, the shipper must be able to document who – in the company – has stated the verified weight. A logon from the shipper's computer can, for example, be sufficient to identify the person concerned.

Are all containers covered by the new regulations?

All containers covered by the International Convention for Safe Containers (CSC) from 1972, as amended, which are to be transported on international voyages are covered by the new regulations. However, containers carried by ro-ro ships on short international voyages are not covered.

A number of transport documents ae used in connection with the carriage by sea of packed containers. In which of these is the VGM required to be declared and is it of importance to any subsequent criminal action?

In principle, the shipper can freely choose which method to use when forwarding the VGM of the packed container. Thus, the shipper can choose a separate document/declaration or he/she can choose to use existing transport documents. However, it must - as stipulated in the executive order - be evident who has declared the VGM and who is, in this context, the shipper of the container concerned. The intention is not that the VGM declaration is to have any (other) consequences for the transport documents used by the industry.

I am a shipping agent and I collect small consignments of goods and pack them into one container. Can we use the weight data provided by the individual parties?

The shipper is to establish the verified weight in accordance with one of the two methods. It does not seem obvious for the shipper to use method 2 in this situation as he does not have the management over the weight data in the individual consignments of goods.

We are shipping agents for a large company and arrange the transport to the shipowners. The company establishes the verified weight in accordance with method 2. Can we (as the shipper) use the weight data from the company in connection with the indication of the verified weight?

The shipper must establish the verified weight based on method 1 or method 2, and this company will also be sanctioned, in case of need, if the information stated is incorrect. Thus, the shipper cannot provide the VGM (Verified Gross Mass) solely based on information from another company.

A shipping agent can pass on the VGM established by the shipper to the master or his or her representative as well as the terminal operator. However, the transport document used for this purpose must state that this is the case.

What is the margin for a VGM (Verified Gross Mass) indication?

In principle, there is no margin of tolerance in connection with the establishment of a VGM since it must be established as accurately as possible. However, in connection with the (suitable) weighing equipment to be used in accordance with method 1, a minor inaccuracy is acceptable within the established weighing intervals. Similarly, there may be minor variations in the pallets, securing devices, dunnage, etc. that are used to secure the goods in a container in accordance with method 2. In order to take account of these operative frames, it will be considered to sanction shippers when the VGM provided deviates from the actual VGM by more than 5 per cent. However, until 30 July 2017, suitable weighing equipment (method 1) that may have deviations of up to 1,000 kg will be accepted.

Can the limit of tolerance stipulated in the executive order be expected to be prolonged?

No, the Danish Maritime Authority has the definite impression that the necessary weighing equipment is available on the market, just as major shippers and container terminals have started to implement it in their operation. Consequently, there is no need to prolong this "interim period".

 Kontakt

Maritime Regulation and Legal Affairs
Steen Møller Nielsen, Senior Adviser
+45 72 19 63 76