'No chance of meeting July 1 Solas deadline' - Fruit SA

A large number of practical
problems – including the lastminute
appointment by the
SA Maritime Safety Authority
(Samsa) of accreditation
agencies – stand in the way
of the July 1 deadline for
the implementation of Solas
regulations on the verification
of the gross mass (VGM) of
packed containers.
One of the primary concerns
highlighted in a comprehensive
document compiled by Fruit SA
is the vital need for all shippers’
container packing facilities to
have their weighing equipment
ordered, installed, calibrated
and certified by the SA
National Accreditation System
(Sanas) accredited laboratory
before July 1.
Furthermore, each weigh
point and shipper using method
2 (adding the mass of every
item in a container to the tare
mass of the container itself
to calculate its VGM) will be
required to undergo an audit by
a Samsa-appointed third party
to verify the weighing process.
Fruit SA commented: “As it
stands, there is only a handful
of approved third-party
certification agents approved by
Samsa to conduct verification
audits.
“Considering that there are
hundreds if not thousands
of ‘shippers’, including those
in the fruit export industry,
that will be required to be
audited in terms of method
2, it is highly unlikely that the
majority of the requirements
will be in place before the July
1 implementation date. In fact
these requirements could take
months to prepare.”
Fruit SA suggested that it
would therefore be advisable
that an extension be applied for
a further 18 months to January
1, 2018.
If that’s not possible, Fruit
SA advised that the local
authorities, terminals and
shipping lines should agree
on measures “to continue
the exporting of containers
without hindrances to trade”.
If this cannot be achieved, it
added that the “ramifications
from a logistics point of view
and the effects on trade would
be catastrophic at best”.
Fruit SA also suggested
that public consultation by
the local authorities on the
Solas amendment was also
conducted at the last minute.
The first official notification
was circulated by Samsa on
June 26 last year and the
official guidelines on January
21 this year. Nothing like
enough time for shippers to be
ready to go by July 1.
Fruit SA also questioned
the validity of a shipper’s
accountability for the mass
of empty containers – as
per section 4 of the Solas
amendment.
“Should accountability be
placed on the ‘shipper’ to verify
the tare mass of containers
since empirical evidence shows
the CSC plated masses to be
inaccurate in many cases –
particularly in the case of reefer
containers,” it added. “Should
it not be that ‘shippers’ are
merely obligated to declare a
VGM pertaining to
the contents of the
container and not
be accountable for
the tare mass of the
container as well?”
Fruit SA’s detailed
compilation included many
other problem areas. These
included technical concerns
about Transnet Port Terminals'
(TPT’s) amendment of the
Navis port management
system to incorporate VGM
detail; the complications of
using weighbridges under
method 1 (to weigh container
and goods together in order
to define the gross mass);
problems around weighing
packed containers and vehicles
together and that the packed
and sealed container be
weighed independently of the
mode of transport; and the
logic behind shippers only
being responsible for declaring
the mass of the goods and
dunnage in the containers.
One interesting suggestion
was that weighbridges and/
or weigh-in-motion solutions
should be implemented at the
applicable entrance and exit
areas of the SA ports, although
Fruit SA recognised that TPT
had point blank refused to
involve itself in the VGM issue,
and that responsibility for it
rested solely on the shippers.
Another issue exclusively
related to perishable, especially
fruit, exports. Fruit contains
>80% water content, and
“moisture loss is a constant
which alters the mass of a
specific piece of fruit”.
A simple study has shown
that the mass of a citrus pallet
can change by 5% in a matter
of a week, according to Fruit
SA. And, it added, “as the Solas
requirement factors in no
measure for mass tolerances
on the VGM declared, this
could be a problem for the fruit
export industry”.
But its overall conclusion
was that the July 1 deadline
was just not on, as too much
still had to be decided for that
date to be effectively complied
with.
Fruit SA is an organisation
formed by the Citrus Growers’
Association (CGA) of Southern
Africa; Hortgro; the SA Table
Grape Industry (Sati); Subtrop;
and the Fresh Produce
Exporters’ Forum (FPEF).