Chain of Responsibility
Chain of Responsibility (CoR)
Chain of Responsibility (CoR), part of Compliance and Enforcement (C&E) legislation, was introduced into Western Australia on 27 April 2015. This legislation imposes obligations on all parties in the supply chain to ensure the weights of sea freight containers and their contents being transported by road are accurately stated. It takes responsibility beyond the drivers and road transport operators to the consignors of the freight, the vehicle owners, the packers, management and receivers. All supply chain participants are required to take all reasonable steps to ensure compliance. See more information on the Chain of Responsibility page, Main Roads WA website. To assist supply chain participants in preparing for CoR legislation, Fremantle Ports and the WA Port Operations Task Force have developed online and smartphone tools. See information about a CoR/SOLAS app for truck drivers and A Guide to Container Weight Declarations below.
What is a Container Weight Declaration (CWD)? Collapse and expand this accordion
Always make sure you have (or can access) a valid Container Weight Declaration (CWD). This will be in hardcopy or electronic format and must contain:
- Container number
- Gross weight - container tare plus contents
- Name and address of responsible entity
- Date of declaration
Ideally, this should also indicate the centre of mass (weight distribution) of the container.
What to do if you have a CWD but think you still may be overloaded? Collapse and expand this accordion
If you have a valid CWD and you still think that your truck may be overloaded (total weight or load distribution on axles):
Contact your controller but do not proceed until clear instructions are received regarding the corrective action to be taken.
It is an offence to enter the Public Road Network if a vehicle exceeds the regulatory or permitted mass, dimension or loading limits.
You do not have a valid CWD? Collapse and expand this accordion
Do not load container until advised
If there is no CWD, contact your controller and refuse to load until you are either:
- Given a CWD, or
- Instructed to leave the container and carry on with other work
Do NOT leave with a container, without a valid CWD
Import Containers within the Fremantle Ports precinct Collapse and expand this accordion
Any party offering a container for transport is obliged to notify the transport operator of any suspected total weight and/or load distribution issues. With this information, if there are still concerns about the load:
- Check with your Controller for any known Customs or Quarantine restrictions in place.
- Subject to alternative instructions, if loaded, proceed to the weighbridge at the Truck Marshalling Area (TMA) in Manoora Close to verify correct weight and centre of mass.
- If you have exceeded a total or axle weight, proceed to one of the designated Control Areas, as directed by your Controller for either:
- opening and eventual repacking, and/or
- to wait for an alternative truck that can transport the container without exceeding a regulatory or permitted mass limit.
DO NOT ATTEMPT TO OPEN THE CONTAINER OR BREAK THE SEALS WITHOUT EXPLICIT INSTRUCTIONS FROM YOUR CONTROLLER.
What has changed concerning the weighing of export containers Collapse and expand this accordion
In May 2014 the 93rd session of the IMO Maritime Safety Committee (MSC) approved changes to the Safety of Life at Sea (SOLAS) Convention requiring mandatory weight verification of containers by shippers.
Australia, as a signatory to SOLAS, has now applied this amendment. It is now in effect
Who is responsible for providing the verified weight? Collapse and expand this accordion
- The shipper. Who is the shipper?
- The Australian Maritime Safety Authority (AMSA) note that their current Order defines the shipper as “any person, organisation or Government which prepares a consignment for transport, and in the case of goods shipped by container or vehicle in less than full container or vehicle load, includes the consolidator of those goods”.
- FCL – the person who packs the container
- LCL – the consolidator of the FCL
- The shipping line and the terminal will rely on the shipper’s signed weight verification to be accurate.
How do I verify my weight? Collapse and expand this accordion
- The changes adopted by the IMO provide for two methods of weight verification:
- Method 1 – Weigh the loaded container; or
- Method 2 – Weigh all contents of the container and add it to the tare weight.
- For Method 2, individual, original sealed packages that have the accurate mass of the packages and cargo items (including any other material such as packing material and refrigerants inside the packages) clearly and permanently marked on their surfaces, do not need to be weighed again when they are packed into the container.
- Nonetheless, with original sealed packages that have a stated weight, visibly printed on the side of the pack, we strongly recommend you confirm the stated weight as correct as the shipper is ultimately responsible for the final recorded container weight.
- Estimations are not permitted and the weight under the guidelines (MSC.1/Circ.1475) with SOLAS requiring use of “calibrated and certified equipment” for this purpose. However, the World Shipping Council has noted that “National enforcement agents may exercise discretion or tolerance in deciding when to initiate further investigations or penalty action”.
- For Australia, at present, equipment is calibrated and certified by the National Measurement Institute (NMI). AMSA does have the flexibility to accept alternative and comparable accuracy standards. An update, expected in the near future, will provide more information about Australia’s position on allowable tolerances for the SOLAS purposes (e.g. to account for factors such as moisture content, etc.).
I’ve got a verified weight, what do I do now? Collapse and expand this accordion
- The shipper is required to provide a signed “verified gross mass’ of the container to the master of the ship (or their representative) and the terminal in advance of the container being loaded and ahead of container cut-off. This can all be electronic.
- The information must be provided in a “shipping document” (Bill of Lading, shipping instructions or a separate communication). Check with your line.
- The information can be provided electronically (including an electronic signature).
- It should clearly highlight that the gross mass is a “verified gross mass”.
- The PRA process through 1-stop is a valid means. If there are any concerns, the matter should be taken up with the shipping line and/or the terminal concerned.
What if I don’t provide a declared weight? Collapse and expand this accordion
- Your container will not be accepted for shipment and, as a result, will not be loaded on board.
- Terminals may turn containers away that do not have a verified weight. In Western Australia, both terminals have indicated that they may allow information to be provided after the terminal has entered the gate but has not yet been loaded, but only under exceptional conditions. You must immediately contact the terminal to clarify any weight information entry difficulties encountered.
- Some terminal operators may, at their discretion, offer a weighing service. This should be checked with the relevant terminal operator.
What are my options to get a verified weigh? Collapse and expand this accordion
- Use a certified and calibrated weighbridge
- There are a number of weighbridges throughout the state. The list of registered weighbridges noted by Main Roads is available from their website.
- Roads WA Registered Weighbridges
- These include two weighbridges operated within the Port precinct –
- Toll Intermodal (Truck Marshalling Area – Kooringa Place)
- Graincorp (Birksgate Road)
- Use certified, calibrated set of scales at your premises to obtain the weight for the individual pack pieces, dunnage etc.
- With this, add the tare of the container to provide a verified gross mass (note: this may not be necessary if the pack piece has a permanently recorded weight note on the item from the manufacturer for the whole pack piece weight, including dunnage, pallets, etc.).
- Obtain certifiable and calibrated load sensor devices to install on existing container handling equipment.
- Consider devices such as certifiable, calibrated Class 4 weigh in motion devices, devices that can fit under the corners of containers to provide weighs, etc.
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