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A Patchy Implementation: A Global Perspective

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Author(s): Matthew Gore, Partner, Holman Fenwick Willan, London, UK

With less than seventy five days left (at the time of writing) before the SOLAS amendments become effective on July 1, 2016, it is taking competent authorities a lot longer than anticipated to come forward with guidance on implementation, enforcement and tolerances. It is expected that many Competent

Authorities will be publishing their requirements shortly for implementation and enforcement in their jurisdictions, leaving very little time for the industry to action these and be ready for July 1. It is clear that different approaches and timetables are being followed in different jurisdictions.

This has been clearly reflected when we canvassed some of our other offices which have also been actively working in this area with clients such as terminals, carriers, forwarders, shippers and others in the container supply chain.

UNITED KINGDOM

Whilst lots of contracting states are clearly working on it, the Maritime & Coastguard Agency (MCA) in the UK is one of the few which has confirmed its requirements and is leading the way by working with European partners to try and provide a harmonised approach. The MCA recently updated its webpage with further details on its approach.

Guidance has been given on what the MCA will expect from those using both Method 1and Method 2, particularly in terms of recordkeeping. The UK enforcement tolerance has also been refined is now as ±5% or ±500kgwhichever is greater. Lower tolerances have been set for modified lifting equipment to be used to establish verified gross mass (VGM)…