Introduction
1 The use and provision of port reception facilities (PRFs) is
fundamental to the overall success of the International Convention for the
Prevention of Pollution from Ships, 1973, as modified by the 1978 and 1997 Protocols
(MARPOL) in its objective of reducing and ultimately eliminating intentional
pollution of the marine environment by ships. Considerable efforts by Party States
and the industry have resulted in an improvement in the availability and adequacy of
PRFs.
2 However, recent work by the Organization suggests that there are still
barriers to the efficient delivery of MARPOL wastes/residues ashore. One such
barrier has been identified as the lack of clear, easy-to-use guidance that outlines
how the shipping community and reception facility providers can best conduct their
operations in order to comply with MARPOL and to facilitate efficient,
environmentally responsible disposal of MARPOL wastes/residues.
3 This Consolidated Guidance is intended to be a practical users' guide
for ships' crew who seek to deliver MARPOL wastes/residues ashore and for port
reception facility providers who seek to provide timely, efficient port reception
services to ships. It provides a basis for establishing best practice procedures,
with an eye towards improving the integration of PRFs into a more comprehensive
waste management scheme in which final disposal of MARPOL wastes/residues occurs in
a manner that protects the environment, with due regard for the health and safety of
workers and the general population. It is based on the fundamental requirements
established in MARPOL and the guidance provided in the Organization's Manual Port
Reception Facilities – How to do it (2016) (the Manual) and the
Guidelines for ensuring the adequacy of port waste reception facilities
(resolution MEPC.83(44)). Building on the Manual and the Guidelines, this Guidance
suggests how modern environmental management systems and procedures can assist with
the improvement of MARPOL wastes/residues delivery ashore. Procedures recommended by
the Organization include communication and reporting procedures and the use of
standardized forms.
4 This Guidance is not intended to provide guidance to Party State
authorities and Governments who wish to implement reception facilities under MARPOL.
The Port Reception Facilities – How to do it (2016) Manual and the
Guidelines for ensuring the adequacy of port waste reception facilities,
as noted above and previously published by IMO, should be referred to for these
purposes.
Terms used in this Guidance
5 This Guidance has been written with the aim of enabling shipowners/operators and
PRF operators to comply with MARPOL. As such, plain language has been used wherever
possible. However, it is important that the terms used in this guidance be
interpreted consistently and in the appropriate context. The following definitions
set out some basic terminology in the context of this Guidance. For complete legal
definitions, applicability and exceptions, reference should be made directly to
MARPOL and its Annexes.
6 Adequacy as used in the MARPOL Annexes means that PRFs meet the
needs of ships using the ports without causing undue delay. PRF operators and users
may refer to the Guidelines for ensuring the adequacy of port waste reception
facilities (resolution MEPC.83(44)), section 3 (How to Achieve Adequacy), or
section 2.3.1 of the Manual Port Reception Facilities – How to do it (2016),
for further information. Section 3.2 of the Guidelines further states that "adequate
facilities can be defined as those which: mariners use; fully meet the needs of the
ships regularly using them; do not provide mariners with a disincentive to use them;
and contribute to the improvement of the marine environment". Additionally, section
3.3 of the Guidelines specifies that the reception facilities must "… allow for the
ultimate disposal of ships' waste to take place in an environmentally appropriate
way".
7 Discharge is defined in MARPOL as any release, however caused, from a ship
and includes any escape, disposal, spilling, leaking, pumping, emitting or emptying.
In this guidance, the term "discharge" refers generally to the types of discharge
regulated under MARPOL.
8 Garbage, as defined in MARPOL Annex V, means all kind of food wastes, domestic wastes and
operational wastes, all plastics, cargo residues, incinerator ashes, cooking oil,
fishing gear and animal carcasses generated during the normal operation of the ship
and liable to be disposed of continuously or periodically, except those substances
which are defined or listed in other Annexes to the Convention. Garbage does not
include fresh fish and parts thereof generated as a result of fishing activities
undertaken during the voyage, or as a result of aquaculture activities which involve
the transport of fish including shellfish for placement in the aquaculture facility
and the transport of harvested fish, including shellfish, from such facilities to
shore for processing.
9
MARPOL wastes/residues is used throughout this Guidance to refer
collectively to all waste streams that are generated on board ships during normal
operations and during cargo operations and are governed by MARPOL, including the
following:
-
.1 MARPOL Annex I: oily bilge water; oily residues
(sludge); oily tank washings (slops); dirty ballast water; and scale and
sludge from tank cleaning;
-
.2 MARPOL Annex II: cargo residues containing
noxious liquid substances (NLS) as defined in MARPOL Annex II; or ballast water, tank
washings or other mixtures containing such substances;
.3 MARPOL Annex IV: sewage;
-
.4 MARPOL Annex V: garbage as defined in MARPOL Annex V (see paragraph 8), including
plastics, food wastes, domestic wastes, cooking oil, incinerator ashes,
operational wastes, animal carcasses, fishing gear, E-waste, cargo
residues not harmful to the marine environment (non-HME) and cargo
residues harmful to the marine environment (HME); and
-
.5 MARPOL Annex VI: ozone-depleting substances and
equipment containing such substances, and exhaust gas cleaning residues.
-
Note: Although some Annex I and II residues are technically cargo residues
(i.e. substances which remain for disposal after the loading or
unloading of cargo), the term "cargo residues" has only been defined by
IMO in the context of Annex V. MARPOL Annex V defines cargo residues as "the
remnants of any cargo which are not covered by other Annexes to the
present Convention and which remain on the deck or in holds following
loading or unloading, including loading and unloading excess or
spillage, whether in wet or dry condition or entrained in washwater but
does not include cargo dust remaining on the deck after sweeping or dust
on the external surfaces of the ship". In the context of Annex V, "cargo residues" refers to cargo
residues that are not governed by Annex I or II (i.e. dry/bulk cargo residues). For complete
definitions and exceptions, please refer to relevant MARPOL Annexes.
Unless otherwise qualified, the terms "waste" and "residue" in this Guidance can be
inferred to mean "MARPOL waste" and "MARPOL residue," i.e. waste streams that are
generated on board ships and are governed by MARPOL.
10 Quarantine waste refers to waste that requires segregation and special
handling due to its potential to spread diseases or plant and animal pests.
11 Reception facility refers to any fixed, floating or mobile facility capable
of receiving MARPOL wastes/residues from ships and fit for that purpose.
Layout of Guidance
12 This Guidance has been developed for use by shipmasters/owners/operators/agents
and port authorities/port reception facility operators, to provide a summary of the
main considerations which should be taken into account when delivering and receiving
MARPOL wastes/residues. It begins with a basic overview of the basis for the use of
PRFs. The remainder of the guidance is divided into two sections: one outlining good
practices for ships and the other focusing on good practices for reception
facilities. Sources of useful supplementary information are referenced at the end of
the guidance. Additionally, in the appendices, standardized formats are provided:
the Format for reporting alleged inadequacies of port reception facilities; an
Advance Notification Form (ANF) for shipmasters/owners/operators to notify port
operators of their MARPOL wastes/residues disposal needs; and a recommended Waste
Delivery Receipt (WDR) format for PRF operators. Appendix 4 contains an overview of
the waste reception facility reporting requirements for both port States and flag
States, the full and effective implementation of which is of paramount importance
for the identification and implementation of the necessary actions to be taken
towards the provision of adequate reception facilities in many ports worldwide.
Corporate and Social Responsibility
13 Since the adoption of MARPOL, global environmental and societal awareness has
grown and developed. This development has introduced new concepts on how to manage
operations in an environmentally sensitive and responsible way. Many shipping
companies and port authorities have implemented environmental management systems
which ensure that their operations are conducted in an environmentally sound manner.
Frequently, environmental objectives are set in order to facilitate the ongoing
improvement, year on year, in terms of a company's environmental impact. Coupled
with this is a growing desire to incorporate the principles of sustainability
alongside that of corporate and social responsibility.
14 This Guidance therefore brings into consideration the need for shipping companies
and reception facility providers to apply the principles of corporate and social
responsibility; to fulfil the obligations relating to all aspects of a company's
operation as frequently found within company environmental management systems; and
to realize the desire of modern companies to continually improve their environmental
performance.
Obligations of Ships and of Port Operators
15 Keeping the seas and oceans clean should be seen as the overriding obligation for
the use and provision of PRFs. MARPOL includes regulations aimed at preventing and
minimizing pollution from ships – both accidental pollution and that from routine
operations. The basis for providing and using PRFs is incorporated in the Annexes of
MARPOL and implementing laws and regulations of State Parties. The following
summarizes the basic obligations under MARPOL and includes other considerations that
ship and port operators should take into account. For specific legal requirements,
users of this Guidance should refer directly to MARPOL and its Annexes or
implementing regulations of individual States Party to the Convention.
16 To complement wastes/residues minimization and management practices on board the
ship (see paragraphs 27 to 34), the shipping industry needs access to adequate PRFs
to enable compliance with the provisions of MARPOL. Therefore, MARPOL places an
obligation on State Parties to provide adequate reception facilities in their ports.
The following regulations stipulate this requirement for each type of MARPOL
wastes/residues identified:
17 In addition to the basic rules in the MARPOL Annexes, ships' operators should be
aware that individual port States have implemented national and regional
requirements which may mandate that ships discharge certain types of MARPOL
wastes/residues to PRFs. Individual port States may also specify the means of
disposal to meet quarantine and other regulatory requirements. Operators should
therefore ensure they have a complete and up-to-date overview of national and
regional requirements relating to PRFs. Such information may be gained directly from
the port State authorities, or via agents in the port, or trade associations
representing the shipping and/or port industries.
18 General obligations under each of the regulations listed above also
state that Parties should communicate information on their PRFs to the Organization.
To this end, the Organization has established the Port Reception Facilities Database
(PRFD) within its Global Integrated Ship Information System (GISIS)footnote. The PRFD relies on up-to-date information being
provided by port States. Port State authorities are encouraged to regularly seek
accurate and up-to-date information from reception facility operators and port
authorities and to maintain entries on the PRFD. Reception facility operators and
port authorities should also be proactive in communicating updated information to
port State authorities. This two-way communication will facilitate the dissemination
of PRF information to the shipping industry.
19 Shipmasters/owners/operators can use the PRFD on the GISIS website to obtain
information on specific PRFs. PRF operators are encouraged to maintain and update on
regular basis current and accurate information regarding their facilities and to
provide such information to authorities so as to ensure the accuracy of information
on the PRFD and that current information is available to shipmasters and
shipowners/operators. Ships' agents, acting on behalf of owners/operators, may also
access the public GISIS website for PRF information.
Special Areas and Emission Control Areas
20 Of particular importance in the ultimate elimination of marine
pollution from ships are the more restrictive requirements in force in Special Areas
and Emission Control Areas (ECAs) as defined in MARPOL. The following is a list of
Special Areas/ECAs to date as adopted within MARPOL (MEPC.1/Circ.778/Rev.2)footnote:
Annex I: Oil
Mediterranean Sea
Baltic Sea
Black Sea
Red Sea (see paragraph 21)
"Gulfs" Area
Gulf of Aden (see paragraph 21)
Antarctic Area
North West European Waters
Oman Area of the Arabian Sea (see paragraph 21)
Southern South African Waters
Annex IV: Sewage
Baltic Sea (to be effective from 1 June 2019)
Annex V: Garbage
Mediterranean Sea
Baltic Sea
Black Sea (see paragraph 21)
Red Sea (see paragraph 21)
"Gulfs" Area
North Sea
Antarctic Area (south of latitude 60 degrees South)
Wider Caribbean region including the Gulf of Mexico and the Caribbean Sea
Annex VI: Air Pollution – Emission Control Areas (ECA)
North Sea (SOX and NOX)
Baltic Sea area (SOX and NOX)
North American area (SOX, NOX and PM)
United States Caribbean Sea area (SO
X, NO
X and PM)
- Note: Requirements may vary for each Special Area
and ECA; therefore mariners should consult the relevant MARPOL Annex or IMO
circularfootnote for specific details.
21 The Special Area requirements for several of these areas have not yet taken effect
because of lack of notifications from MARPOL Parties whose coastlines border the
relevant Special Areas on the existence of adequate reception facilities
(regulations 38.6 of Annex I and regulation 8.2 of Annex V). While this remains the
case, the shipping and port industry should endeavour to meet the requirements as if
the Special Area status of those areas had taken effect, in the spirit of MARPOL.
22 Shipowners/operators and port operators should be conscious that more stringent
restrictions in Special Areas and ECAs further emphasize the importance of the
general obligations to provide adequate reception facilities for MARPOL
wastes/residues. In all cases where shipping companies encounter inadequate
reception facilities, this should be reported accurately and in a timely manner via
the ship's flag State to the Organization and to the appropriate port State
authorities or port operators, using the suggested format for reporting (see
appendix 1).
Good Practices for Shipmasters, Shipowners and Operators
Considerations prior to delivery of MARPOL wastes/residues ashore
23 Efficient delivery of MARPOL wastes/residues ashore relies on advance planning.
The following sections outline ways in which considerations for delivery of MARPOL
wastes/residues ashore can be integrated into a ship's operating procedures in order
to minimize delays and unexpected costs and improve environmental management
practices. Good waste management strategies should be incorporated into voyage
planning.
Logistical and commercial arrangements
24 Consideration should be given to the logistical and commercial arrangements which
may be specified in shipping contracts (charter party agreements) between ship
operators and cargo owners. Such arrangements should take into account the need to
discharge MARPOL wastes/residues ashore to reception facilities and should not
compromise, but rather facilitate, the ship operator's ability to comply with
obligations under MARPOL. Examples of logistical and commercial considerations might
include allowing sufficient time in port to complete transfer of MARPOL
wastes/residues and ensuring that disposal costs are accounted for in charter
agreements when appropriate. Such considerations are especially important when cargo
tank pre-washes are required for certain Annex II residues and when charter
agreements specify tank or cargo hold cleaning after discharging cargoes.
Minimization and management of ship-generated wastes/residues
25 Although not a direct requirement of MARPOL, minimizing the wastes/residues
generated on board ships represents an environmental best practice, and should be
considered in a ship's overall waste management practices.
26 The most effective way of reducing ship-generated wastes/residues is to reduce
materials that become waste at the source. Efforts should be made to minimize
packaging from ship stores, for example, by establishing an agreement with the
supplier to accept the return of the packaging upon delivery, or to reduce the
amount of packaging.
27 Developing an agreement with suppliers and manufacturers is not only important for
more general waste categories such as plastics, but essential for other maritime
specific wastes such as time expired pyrotechnics; used ropes, tails and wires; time
expired medicine; and batteries. The supplier and/or manufacturer should be able to
provide the specialist facilities for treatment or disposal of these products and
materials.
28 Onboard waste management will also assist in minimizing
ship-generated wastes/residues. Ship operators and shipbuilders should consider
further the design of new ships to enhance waste treatment on board and consider
introducing operational measures which can improve efficiency for existing ships.
Further information on shipboard garbage handling and storage procedures and
minimizing the amount of potential garbage is provided in the 2017 Guidelines for
the implementation of MARPOL Annex V (resolution MEPC.295(71)). In addition, an ISO standard for the
management and handling of shipboard garbage (ISO 21070:2011) has been developed.
For ships of 100 gross tonnage and above, and ships which are certified to carry 15
persons or more, information with regard to onboard management of garbage will also
be included in the Garbage Management Plan (2012 Guidelines for the Development
of Garbage Management Plans (resolution MEPC.220(63)).
29 In relation to the minimization of oily waste, an increased familiarity with the
ship's engine-room treatment systems coupled with the crew's training in oily waste
management and recording will assist in reducing the amount of waste produced and
improve the overall on-board management of oily waste. The use of an Integrated
Bilge Water Treatment System (IBTS) will facilitate segregation of oily waste,
allowing for the storage of oil sludge, oil-water mixtures and clean water
separately.
30 Ships' crew need to understand the correct use of, and entries to, the
Oil Record Book, the Cargo Record Book and the Garbage Record Book. This will help
to ensure that any management system implemented can be easily monitored and
audited. Industry associations such as INTERTANKO and ICS may provide useful
guidance on the correct use of such record books. Reference should also be made to
the Guidance for the recording of operations in the Oil Record Book Part I –
machinery space operations (all ships) (MEPC.1/Circ.736/Rev.2).
31 If space permits, onboard waste management plans should take into
account the possibility of being able to recycle certain garbage types. The
segregation of garbage according to the requirements of MARPOL Annex V (e.g. plastics; food wastes; domestic wastes; cooking
oil; incinerator ashes; operational wastes; cargo residues; animal carcasses;
fishing gear) should also allow for the delivery of garbage in certain recyclable
categories.
32 To facilitate the landing of recyclable residues/waste, ship operators should
consider establishing contracts with facilities in ports that are visited on a
regular basis. This will fulfil both the need to use a reputable supplier as per
most environmental management systems and facilitate the discharge of segregated
waste ashore on each port visit. Where appropriate reception facilities for
segregated and/or recyclable wastes are not provided in a port, shipowners/operators
are encouraged to request that such facilities are developed in conjunction with the
recycling capability of the locality or region.
Communication and advance notification
33 Individual ports may need to comply with varying local requirements for
specialized handling (such as quarantine) of certain types of MARPOL
wastes/residues, such as animal, plant and food wastes generated on board the ship.
Therefore, ship operators should check with local agents, port authorities, harbour
masters or reception facility providers for port-specific requirements prior to
arrival in order to plan for and accommodate any special handling requirements for
that particular port, including any additional segregation that may need to take
place on board well in advance of arrival. This information should be incorporated
into the company's environmental management plan and should be taken into
consideration in voyage planning.
34 As noted in paragraph 18, IMO's PRF Database, accessible online through the GISIS
website, can be a good source of information about the reception facilities
available at ports worldwide. Users are required to first register by creating a
username and password.
35 In some ports, for logistical reasons, the providers of port reception facilities
may require advance notification from the ship of its intention to use the
facilities. Further information on this requirement is provided in section 4 of the
Guidelines for ensuring the adequacy of port waste reception facilities
(resolution MEPC.83(44)). Providing advance notification to the reception facility
of the type and quantity of MARPOL wastes/residues on board and the type and
quantity intended to be delivered will greatly assist the reception facility
operator in receiving the materials while minimizing any delay to the ship's normal
port operation. General recommended practice is to provide at least 24 hours'
notice, although specific requirements may vary by reception facility. If a ship
visits a port on a regular basis, a standing arrangement with the PRF may prove to
be most efficient. Shipmasters are recommended to use the standardized Advance
Notification Form developed by the Organization (see appendix 2). Port authorities,
agents and facility operators are urged to accept the standardized format; however,
some operators may require an alternate form.
Considerations during MARPOL wastes/residues delivery
36 During delivery of MARPOL wastes/residues, appropriate procedures as drawn up in
the ship's Safety Management System (SMS, see ISM Code) should be followed.
37 Following delivery, the master should request a Waste Delivery Receipt to document
the type and quantity of MARPOL wastes/residues actually received by the facility.
IMO has standardized the format of this document to facilitate its use and
application and in order to provide uniformity of records throughout the world
(appendix 3). Corresponding records, receipts or certificates of the delivery shall
be kept in the Garbage Record Book (for a minimum of two years) and the Oil Record
Book (part I for all ship types and part II for oil tankers) and the Cargo Record
Book for chemical tankers.
38 Ship operators play a critical role in assisting port States with their obligation
to provide adequate PRFs for ships. Since the possibility for improving reception
facilities is dependent, at least partly, on the receipt of adequate information
about alleged inadequacies, shipping companies should be encouraged to include the
provisions for reporting alleged inadequacies of port reception facilities in their
procedures for shipboard operations required under section 7 of the ISM Code. As
part of the ship's SMS, the master should be required to complete a report on
encountering an inadequate PRFs. The format for such a report is provided in
appendix 1, which is also available through the Port Reception Facility section of
the GISIS website. Completed reports should be forwarded to the flag Administration
and, if possible, to the Authorities of the port State.
39 Flag States are requested to distribute the format in appendix 1 to ships and urge
masters to use it to report alleged inadequacies of port reception facilities to the
Administration of the flag State and, if possible, to the Authorities of the port
State. Flag States are also required to notify IMO, for transmission to the Parties
concerned, of any case where facilities are alleged to be inadequate, and to inform
the port State of the alleged inadequacies.
40 Notification should be made as soon as possible following the completion of the
alleged inadequacies reporting format and should include a copy of the master's
report, together with any supporting documentation.
41 Port States should ensure the provision of proper arrangements to consider and
respond appropriately and effectively to reports of inadequacies, informing IMO and
the reporting flag State of the outcome of their investigation.
42 The alleged inadequacy report together with the follow-up action received from the
port State will be published in the GISIS PRF Database.
Good Practices for Port Reception Facility Operators
Communication
43 In order to provide efficient PRF services that meet the needs of ships calling at
a port without causing undue delay, port authorities should prepare a Port Waste
Management Plan and should ensure that relevant information about the reception
services available and associated costs are communicated to ship operators well in
advance of the ship's arrival.
44 It is useful for ship operating companies to be able to plan the delivery of
MARPOL wastes/residues well in advance of the ship's next port call, especially if
the port has more stringent requirements that might necessitate additional
segregation of waste on board prior to arrival, such as quarantine segregation. As
noted above, to facilitate ships' planning, port authorities or PRF providers are
urged to communicate to their country focal points accurate and up-to-date
information about the reception facilities available at the port. This information
can then be communicated to the shipping industry via the GISIS PRF Database.
45 At a minimum, the information uploaded and made available in the PRFD should
include type of facilities, capacity of the facilities and the contact point.
Additional information that would facilitate ships' planning might include contact
details for the port authority or harbour master, a link to the port website, a link
to the Port Waste Management Plan, and information relating to fees/cost to use
facilities. A good example is the information provided in material published by the
Port of Rotterdam (available at: www.portofrotterdam.com). Such additional
information may be downloaded electronically as required, and could provide further
instruction to ships regarding procedures for using the facilities (including, for
example, specific local requirements for quarantine waste).
46 Port authorities and reception facility providers should request shipmasters to
provide advance notice of MARPOL wastes/residues delivery in order to ensure that
the necessary receptacles and vehicles are prepared for receipt of the material. To
facilitate the notification process, port authorities and reception facilities
should accept the standardized Advance Notification Form (appendix 2). Use of the
standardized form will allow the shipmaster and operator to prepare in advance a
system for generating such forms and avoid having to complete a different form for
each port or facility visited.
Port reception practices
47 Although legal requirements for PRFs will vary depending on the port State's
implementing legislation, good practices for PRFs should include procedures that
facilitate better integration with shipboard and landside wastes/residues management
practices. Such integration and cooperation with inland waste disposal operations
should allow ultimate disposal of ship-generated wastes/residues to take place in an
environmentally appropriate manner.
48 The reception facility should be adequately prepared to receive MARPOL Annex V
wastes/residues as segregated on board and should supply suitable receptacles to
facilitate the landing of segregated waste for recycling. Procedures for reception
of segregated wastes/residues should parallel the standards for the Management and
Handling of Shipboard Garbage as specified in ISO 21070:2011. PRF operators and port
authorities within State Parties should work with national and local government
officials, regional administrators, commercial interests, and local waste disposal
infrastructure managers to develop landside waste disposal strategies, including
waste segregation, that encourage reduction, reuse and recycling of ship-generated
wastes/residues landed ashore at PRFs. Reception facility providers should seek out
resale/recycling options for reusable/recyclable waste when not prohibited by local
laws.
49 In the case of oil, noxious liquid substances and other dangerous
goods or harmful or hazardous substances, port and reception facility operators
should adhere to the guidance provided in relevant publications such as the
International Safety Guide for Oil Tankers and Terminals (ISGOTT), or the
International Maritime Dangerous Goods (IMDG) Code.
50 The reception facility should also be adequately prepared to receive MARPOL
wastes/residues in accordance with any local quarantine requirements, for example by
providing suitably sealed receptacles and ensuring that MARPOL wastes/residues can
be transported and disposed of in accordance with regulations. Port State
authorities should also be aware of the need for appropriate treatment and disposal
sites and should seek to ensure that these are available through public or private
arrangements.
51 The necessary connection arrangements for the discharge of machinery oily bilge
water and oil residues (sludge) are provided for in regulation 13 of MARPOL Annex I.
These standard dimensions for flanges and discharge connections apply to all ships
and should therefore allow the reception facility to standardize its own connection
pipes accordingly.
52 Following delivery, the reception facility should provide the master with a Waste
Delivery Receipt (WDR). IMO has standardized the format of the WDR to facilitate its
use and application, as set out in appendix 3.
53 Although the port structure in a State Party may or may not accommodate
cost/pricing schemes and/or other incentives for MARPOL wastes/residues delivery
ashore, reception facility services should be provided at a reasonable cost. The
Guidelines for ensuring the adequacy of port waste reception facilities
(resolution MEPC.83(44)) (section 3.2) define "adequate" facilities as those which
"do not provide mariners with a disincentive to use them", and further stress that
unreasonably high costs may deter use of PRFs (section 5.2).