The letter to Admiral Paul F. Zunkunft lauds remarks from Rear Admiral Paul Thomas, who has written on the agency's Maritime Commons Blog that the SOLAS regulation “provides great flexibility in how compliance can be achieve by carriers who are working with their business partners.”
The groups signing the letter, such as the Agriculture Transportation Coalition, American Farm Bureau Federation and Wine and Spirit Shippers Association, say Thomas has shown “interest in balancing the need to assure safety at marine terminals and on ships, while allowing cargo to move into and through US marine terminals without disruption and delay, and to enable US exports to be globally competitive.”
Their position is at odds with a letter sent to Zunkunft earlier this month by the World Shipping Council, in which the group was critical of comments made by Thomas about the verified gross mass (VGM) requirement, asking that the USCG reconsider its position toward enforcing the new regulation in the SOLAS convention.
The VGM rule goes into effect July 1 and requires shippers to provide the verified gross mass of containers before they are loaded on ships.
“We support the Admiral’s view that if the shipper provides the cargo mass weight, to which the carrier adds the weight of the container, then the intent of SOLAS is achieved," the agriculture groups wrote. "In fact, several ocean carrier executives have advised that such a process would be practical.
“The reason for our concern, and appreciation of Admiral Thomas’ guidance, is that some ocean carriers, citing this SOLAS amendment, are demanding that the shipper certify both the cargo and the carrier’s container. This is contrary to the practical realities of our US export maritime commerce and fundamentally flawed conceptually. (It would be similar to demanding that a soybean shipper certify to the railroad the weight of the railcar itself.)”
The agriculture groups say the SOLAS “amendment, unless applied rationally in the manner suggested by the Admiral (Thomas), would create U.S. supply chain disruption and delay, competitive disadvantage for US exporters.”
“There has not been shown any need, in the interests of safety and accurate cargo weight reporting, to impose the unreasonable new requirement that the shipper tell the ocean carrier how much the carrier’s own equipment weighs," they added. "The Coast Guard’s position is reasonable and consistent with safety and competitiveness of US international commerce.”
The agriculture shippers complain “ocean carrier demands that an individual employee of the U.S. exporter company personally certify the weight of the ocean carrier’s container by entering his or her name on the EDI (electronic data interchange) document for that particular shipment, are being rejected. Many U.S. corporations will not allow their employee to certify the weight of and assume liability for equipment that the corporation does not own, manage, control, and in fact may not even see."
They also contend "there has not been shown any need, in the interests of safety and accurate cargo weight reporting, to impose the unreasonable new requirement that the shipper tell the ocean carrier how much the carrier’s own equipment weighs."
"The Coast Guard’s position is reasonable and consistent with safety and competitiveness of US international commerce," the shipper associations wrote.