Fee Modernization Proposal: Marine Cargo

Canada Shipping Act, 2001

Cargo, Fumigation and Tackle Regulations

Port Wardens Tariff

Board of Steamship Inspection Scale of Fees

Table of contents

Executive Summary

The primary responsibility of Transport Canada's Marine Safety Cargo Program (the Program) is to verify the safe loading and stowage of higher risk cargoes. In order to maintain the safety of vessels, personnel, and the environment, the Program continues to adapt to meet new international standards in the area of marine cargo safety, while at the same time providing efficient and timely service to the marine cargo industry in Canada. Specifically, the Program conducts:

  • Mandatory marine cargo inspections for three regulated cargoes: grain, timber on deck and concentrates;
  • Inspections under international standards and inspections at the request of “interested persons” relating to solid bulk dangerous goods and packaged dangerous goods; and
  • Verification of shipper's procedures by ensuring marine shippers comply with international shipping standards.

All vessels loading in Canadian waters that have regulated cargo bound for export, such as grain, timber on deck and concentrates are subject to mandatory cargo inspections. Prior to loading, Transport Canada (TC) inspects a vessel to ensure it is fit to carry the proposed cargo. This inspection verifies the stability and cargo distribution calculations and conditions of the cargo holds of the vessel. During loading, TC can be called to verify continuous application of the regulations. After loading, a final survey is carried out to ensure the vessel is not overloaded and that the cargo is properly stowed and secured. Currently, there are over forty fees spread out over three separate regulations relating to these inspection services. TC is proposing to reduce the number of mandatory marine cargo inspection fees from forty to two. Under this proposal, TC would charge a proposed fee of $1,900 for days on which a certificate is issued and another fee of $512 for days when an inspector is requested to be available, but does not issue a certificate.

The Program is also responsible for conducting inspections relating to bulk and/or packaged dangerous goods in containers on a random basis at high volume ports pursuant to the International Maritime Organization (IMO) inspection regime. These IMO Conventions and Codes are incorporated by reference in different acts and regulations. When a major deficiency or defect is found, TC detains the container until it is restored to a safe condition. Additionally, under the Cargo, Fumigation and Tackle Regulations (CFTR), TC conducts inspections of vessels on which solid bulk dangerous goods and/or packaged dangerous goods are loaded, carried or unloaded at the request of an “interested person” (typically the marine carrier). To simplify the current fee structure of over forty possible fees, TC is proposing a flat fee of $1,500 for these inspections on request.

Finally, the Program is responsible for the verification of shippers' procedures to ensure that shippers comply with international shipping requirements. Specifically, TC inspectors review and approve the procedures established by the shipper regarding sampling, testing and controlling of the moisture content of a cargo that may liquefy. There are currently no fees associated with these services and TC is proposing to introduce fixed fees – one fee of $2,500 for Initial or Modification of verifications of shippers' procedures and another fee of $1,250 for Intermediate or Renewal of shippers' procedures verifications.

All services provided by this Program are provided twenty four hours a day, seven days a week and require a quick turnaround to avoid costly delays for stakeholders. Due to the time-sensitive nature of the shipping industry, TC marine inspectors are often on call, required to travel, and are frequently asked to work overtime.

The existing fees for these services have not been adjusted in approximately 20 years despite inflationary increases in wages, transportation and equipment; updated requirements under International Codes; increase in exports; and modern shipping and handling methods and ship designs. The modernization of this fee regime will better reflect the true cost to TC of providing these services and will simplify the fee structure for stakeholders and TC.

In preparing new fees for the Program, TC performed a rigorous costing analysis, determining that the estimated full cost of the Program is $7.6 million. This estimate reflects a four-year average of the cost of providing these services, covering fiscal years 2014-2015 to 2017-2018. Currently, TC is recovering 67 percent of the overall program costs through existing fees.

By implementing a modern fee regime that requires the beneficiaries of services to pay a greater portion of the costs for these services, TC is promoting better balance between service recipients and Canadians. It would also ensure that TC can address future growth in demand and continue to meet its service standards, including any new future international safety requirements under IMO Conventions or Codes.

The proposed fees were established taking the following factors into consideration:

  • The benefit these services provide to companies and individuals;
  • The fees other jurisdictions charge for similar services;
  • The economic context of the marine industry, including stakeholder ability to pay fees; and
  • The impact of rising fee levels on the industry.

The proposed fees would establish a new average cost recovery rate for marine cargo inspection services of 91 percent. For each inspection of bulk and packaged dangerous goods, the proposed fee of $1,500 would create a new cost recovery rate of 52 percent. Finally, for verification of shippers' procedures, two proposed fees of $2,500 and $1,250 respectively create a cost recovery rate of 75 percent.

By implementing a modern fee regime that asks the beneficiaries of services to pay a greater portion of the costs for these services, TC is promoting a better balance between the financial burden borne service recipients and by Canadians. This Fee Modernization initiative is part of a broader TC transformation plan to modernize our laws, regulations and services.

1.0. Context

Canada's marine transportation sector relies on, and benefits from, services provided by Transport Canada (TC). The main responsibilities of the Marine Safety Cargo Inspection Program (the Program) is to ensure the safe loading and stowage of regulated cargoes, namely grain, timber on deck and concentrates. These types of cargoes can pose a number of serious risks to the structural integrity of vessels, the safety of personnel and the protection of the environment. For example, concentrates pose an inherent risk of liquefaction due to high moisture content. This liquefaction could impair the stability of a vessel and possibly result in the loss of that vessel at sea. Risk of asphyxiation from lack of oxygen in the cargo hold of vessels loaded with such cargoes is also possible. Consequently, the international community established standards and procedures for the proper loading and unloading of bulk carriers, ensuring stability of the vessel, proper cargo distribution and ultimately the safety of its personnel. As a major exporter of bulk cargo, Canada has established a federally regulated regime based on international standards that ensures safe bulk cargo handling.

While the landscape of the industry has changed over the last twenty years, with advancements in technology, infrastructure and operations, TC's fees for marine cargo services have failed to keep pace with this changing and dynamic operating environment. TC's existing fees have not taken into consideration inflation, cost of service delivery, new services, amendments to international conventions and infrastructure and technology improvements. As a result, TC has been allocating an increasing and substantial portion of its resources to deliver marine safety services.

Furthermore, the current fee regime for marine cargo services is scattered throughout various regulations, and is considered overly prescriptive and needlessly complex. This results in confusion, inconsistency, and unpredictability for the industry. For example, the current fee regime is a collection of forty different fees, representing a combination of fixed fees, tonnage-based fees and hourly fees. In order for marine carriers to understand and predict the fees they are charged, they have to review three separate regulations:

  • Cargo, Fumigation and Tackle Regulations (CFTR) – mandates the inspection of regulated cargo bound for export. These regulations set out the procedures and steps that must be followed to ensure the safe loading and stowage of specific cargoes, namely grain, timber on deck and concentrates. The fees listed in these regulations are specific to inspections of vessels loading, carrying or unloading dangerous goods in bulk or packaged form at the request of an “interested person”;
  • Port Wardens Tariff (PWT) – sets the fees for regulated marine cargo inspections. The PWT sets out a table of fees for damage surveys, disputes, grain surveys, timber deck surveys, concentrates surveys and additional fees, such as travel and out-of-hours duty rates; and
  • Board of Steamship Inspection Scale of Fees (BSISF) – is used to charge the standby fee that an inspector applies when he/she is requested to be on call or made available, either continuously or during specified periods, to survey or inspect a ship or perform a service. This regulation is also used to charge the Out-of-Hours duties fees, if applicable, when carrying an inspection other than regulated cargo and/or vessels loading, carrying or unloading dangerous goods in bulk or packaged form.

This Marine Cargo Fee Modernization Proposal seeks to simplify the current Marine Cargo fee structure. This proposal covers TC's marine cargo services, which can be categorized under three broad headings: Marine Cargo Inspections; Inspection of Bulk and/or Packaged Dangerous Goods; and Verification of Shippers' Procedures. A brief description of these services is provided below.

1.1. Marine Cargo Inspections

In Canada, ships carrying certain types of cargo (grain, timber on deck, and concentrates) for export must undergo mandatory inspections. These inspections, conducted by TC, ensure the safe loading, stowing and securing of such cargoes. Based on the results of the inspections, certificates of Readiness to Load and Fitness to Proceed are issued accordingly.

The safe loading of these cargoes is essential to ensuring the safety of the vessel and personnel for the following reasons:

  • Grain: Grain is defined as wheat, corn, oats, rye, barley, rice, pulses and other seeds and the processed form of seeds whose behavior is similar to that of seeds in their natural state. Grain flows, and must be restricted in its movement to ensure the vessel's stability. Therefore, the actual final loaded condition must be carefully checked.
  • Concentrates: Concentrates are materials that are obtained from a natural ore through a process of enrichment by physical or chemical separation and removal of unwanted elements. Mined minerals (i.e. iron ore, coal, metals, etc.) are extracted from rock and soil through a process of crushing and washing, which results in the retention of a certain amount of moisture even at the time of loading. As such, they have a tendency to liquefy during transportation. These cargoes are very heavy and could cause stresses on the structure of the vessel. Therefore, the cargo must be properly distributed throughout the length of the vessel, and the actual final loaded condition carefully checked.
  • Timber on deck: Timber is defined as sawn wood or lumber, cants, logs, poles, and pulpwood. It does not include pulp or similar cargo. Timber is stowed on deck and is exposed to the elements, such as high winds and breaking seas. These elements could cause shifting of the timber and pose a danger to the vessel and its crew. Inspectors ensure, for example, proper safety precautions relating to stability, lashings and closure of openings, covers, ventilation pipes, railing and protection for the crew.

TC ensures that ship operators comply with Canadian and international requirements, such as the International Convention for the Safety of Life at Sea (SOLAS Convention) and associated Codes, Standards or recommendations, to avoid mistakes in calculations, and cargo securing and distribution.

1.2 Inspection of Bulk and/or Packaged Dangerous Goods

TC is responsible for the inspection of vessels on which dangerous goods in solid bulk and/or packaged form are loaded, carried or unloaded, such as ammonium nitrate based fertilizers and explosives. These inspections are carried out at the request of an “interested person”. While there is no statutory definition of an “interested person”, in practice, the term has been accepted to mean a person with a direct relation to the cargo (e.g. the shipyard operator, ship owner or ship operator or authorized representative). To provide further clarity around this term, “interested person” will be defined in the amended fee regulations.

1.3 Verification of Shippers' Procedures

Pursuant to the CFTR, every shipper of cargo to be loaded in Canadian waters for export, must comply with the SOLAS Convention, specifically the International Maritime Solid Bulk Cargoes Code (IMSBC Code). The IMSBC Code states that the competent authority of the port of loading (in this case TC) shall approve the procedures established by the shipper regarding sampling, testing and controlling of the moisture content of a cargo which may liquefy. In accordance with the IMSBC Code, TC performs four different types of verification services:

  • Initial: the purpose of initial verification is to ensure that the procedures comply with the provisions of the IMSBC Code, that personnel involved have received appropriate training and the required equipment is available in conformity with the description included in the procedures.
  • Intermediate: the intermediate verification takes place on the anniversary date of the Letter of Approval required under the IMSBC Code. There is always at least one intermediate verification.
  • Modification: when a shipper modifies their procedures, they must notify TC and a re-verification, similar to the initial verification, will take place.
  • Renewal: a renewal verification is done at intervals specified by the authority of the port of loading, but cannot exceed five years. This verification would ensure that the approved procedures still comply with the applicable provisions of the IMSBC Code in force at the time of the renewal verification.

Upon completion of the verification procedures, a letter of approval is provided to the shipper and required to be kept on hand and furnished upon an inspector's request.

2.0. Issue

Due to the time-sensitive nature of the shipping industry, TC's marine cargo services are provided 24 hours a day, seven days a week. To minimize delays and the time vessels spend at port, inspections are often requested and occur at all hours of the day and during any day of the week, including holidays and weekends. In addition, there is often extensive travel for the inspectors to reach the port or location of loading. As a result, TC's marine cargo services are amongst the most resource intensive services provided by the Department.

The Canada Shipping Act, 2001 gives TC the authority to charge fees for services. However, the majority of TC's marine fees have not been updated in nearly twenty years, including the fees currently charged under the Marine Safety Cargo Inspection Program. Currently, TC recovers approximately 67 percent of the total cost of providing services related to the Program; leaving the remaining 33 percent of costs funded by taxpayer dollars. Moreover, the Department estimates that approximately 90 percent of the benefits from these services go directly to private entities, who are primarily foreign-owned.

3.0. Objective

Under this Marine Cargo Fee Modernization Proposal, TC proposes to:

  1. Update its marine cargo fee regime by consolidating and simplifying its fee structure;
  2. Amend and add new fees to better reflect the costs of delivering services; and
  3. Set fees that better reflect the principle that those who benefit the most from these services should pay a greater share of the costs.

Updated marine cargo fees will lessen the burden these costs place on the Canadian taxpayer. Updated fees will also allow TC to ensure that the Marine Safety Cargo Inspection Program continues to have the resources it needs to provide timely and high value service to industry.

4.0. Fee Modernization at Transport Canada

Some TC services have been provided to individuals and industry free of charge while fees for other services have not been updated in twenty years and do not reflect the real cost to the Department to deliver them. As a result, Canadian taxpayers are bearing a greater proportion of the costs of providing services to transportation stakeholders.

Furthermore, the Service Fees Act (SFA) recently changed the legal framework governing fee setting. The SFA represents the Government's commitment to modernizing its services and delivering value to Canadians. The SFA applies to all fees that currently exist and the ones that TC plans to introduce.

Over the next few years, TC will:

  • Introduce new fees;
  • Increase existing fees; and
  • Simplify fee structures.

Fee modernization will be achieved mainly through regulatory changes. It is expected that more than 600 fees will be updated or created through this initiative. Fee modernization is part of a broader plan to:

  • Modernize our laws, regulations, rules and standards;
  • Ensure we continue to uphold safety and security; and
  • Ensure TC can continue support innovation in the transportation sector.

5.0. Current Environment

5.1. Statutory Framework

The Program provides important services by inspecting and verifying vessels and cargoes to align with international standards and protecting the safety of vessels, personnel and the environment. Such inspections require time sensitive service standards given the nature of the industry. Unnecessary delays lead to significant costs to the stakeholder.

The fees related to these marine cargo services are currently provided in three separate regulations:

  • Port Wardens Tariff (PWT)
  • Cargo, Fumigation and Tackle Regulations (CFTR)
  • Board of Steamships Inspection Scale of Fees (BSISF)

Each regulation identifies the hourly rates of an inspector depending on the day and time of the inspection. The PWT has a table of fees, but there is no mention of the standby fee, which is only addressed in the BSISF. The fees prescribed in the CFTR relate to inspections of vessels loading, carrying or unloading dangerous goods in solid bulk and/or packaged form, carried out at the request of an “interested person”.

5.1.1 Marine Cargo Inspections

The existing fee structure is a combination of fixed fees, tonnage-based fees and hourly fees, which makes expected total fees to be paid difficult to calculate for service recipients, resulting in uncertainty, inconsistency and unpredictability for the industry. In the last five calendar years, from 2013 to 2017, an average of 1,508 inspections were carried out annually representing 61 million metric tonnes of cargo.

5.1.2 Inspection of Bulk and/or Packaged Dangerous Goods

Fees are charged when an inspection is made pursuant to a request from an “interested person” to inspect vessels on which dangerous goods in solid bulk and/or packaged form are loaded, carried or unloaded.

Over the last three fiscal years, there were nine, four and eight requests for inspection by an “interested person”.

5.1.3 Verification of Shippers' Procedures

Pursuant to the CFTR, approval of shippers' procedures (as described in section 1.3 above) is now a prerequisite and considered part of the mandatory inspections of vessels for loading of concentrates. In order for the inspector to issue a Certificate of Readiness to Load, the shipper must provide a copy of the approval letter to the ship's captain, who must furnish it upon request. There are currently no fees associated with these services.

5.2. Current Fees

The Canada Shipping Act, 2001 provides the authority to recover fees for services provided by the Minister of Transport. The relevant statutory provisions are listed below and can be found on the Department of Justice website at: http://laws-lois.justice.gc.ca/eng/acts/C-10.15/page-6.html#h-20.

Regulations — Minister of Transport

35(1)(g) respecting the setting and payment of fees for services provided in the administration of this Part or Part 2 (Registration, Listing and Recording), 3 (Personnel), 4 (Safety) 6 (Incidents, Accidents and Casualties), 7 (Wreck) other than section 163, 8 (Pollution Prevention and Response — Department of Transport and Department of Fisheries and Oceans) to the extent that the Minister of Transport is responsible for that Part, 9 (Pollution Prevention — Department of Transport), 10 (Pleasure Craft) or 11 (Enforcement— Department of Transport) or the regulations made under any of those Parts or under subsection 136(1);

5.2.1.

The relevant provisions for the Cargo, Fumigation and Tackle Regulations can be found on the Department of Justice website at: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2007-128/index.html

5.2.2.

Items 6 to 19 of the schedule of the Port Wardens Tariff that relate to grain, timber on deck and concentrates and can be found on the Department of Justice website at: http://laws-lois.justice.gc.ca/eng/regulations/SOR-79-154/index.html.

5.2.3. The relevant statutory provision for the Board of Steamship Inspection Scale of Fees can be found on the Department of Justice website at: http://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._1405/FullText.html?wbdisable=false.

See Appendix B for details on the applicable statutory framework.

5.3 Existing Fees

5.3.1 Marine Cargo Inspections

The services that currently have associated fees can be found in the CFTR, the PWT and the BSISF. The list of fees from those three regulations can be found in Appendix C.

Loading of these cargoes require detailed care and carriage. TC carries out these inspections to ensure loading is correct and all necessary precautions are taken.

The following is a description of the services currently provided by the Program for which fees are being charged:

Grain

  • Survey of the condition of any ship
  • Preliminary Inspection Certificate (written statement)
  • Readiness to Load Inspection
  • Fitness to Proceed Inspection

Concentrates

  • Survey of the stowage of concentrates on board a ship
  • Preliminary Inspection Certificate (written statement)
  • Readiness to Load Inspection
  • Fitness to Proceed Inspection

Timber

  • Inspection During Loading (if required)
  • Preliminary Inspection Certificate (written statement)
  • Readiness to Load Inspection
  • Fitness to Proceed Inspection

5.3.2 Inspection of Bulk and/or Packaged Dangerous Goods

Fees are charged when an inspection is made pursuant to a request from an “interested person” to inspect vessels on which dangerous goods in solid bulk and/or packaged form are loaded, carried or unloaded.

5.3.3 Verification of Shippers' Procedures

There are no existing fees to verify shippers' procedures.

5.3.4 Applicable to all Inspections

Standby Fee

  • A standby fee is payable for each calendar day or portion of a calendar day for which an inspector is on call or made available.

See Appendix C for a detailed list of the Program's current fees and service standards.

6.0. Cost Analysis

TC undertook a rigorous costing exercise to estimate the cost of delivering the Marine Cargo Inspection Program. The exercise adhered to the Treasury Board of Canada Secretariat's (TBS) Guidelines on Costing and followed TC's Cost Recovery Costing Policy to arrive at a defensible and transparent cost estimate.

6.1. Determining Full Cost

Costing for cost recovery purposes requires the calculation of the “full cost” of delivering an activity. According to the Financial Administration Act and applicable TBS guidance, full cost is the allowable upper legal limit that can be recovered through cost-based fees. Full cost represents the departure point for determining pricing options. A full cost estimate comprises all relevant resource costs incurred to deliver an activity or provide a service, including direct and indirect costs, specifically:

  • Employee salaries;
  • Operating and maintenance;
  • Amortization of capital assets;
  • Program support;
  • Internal services;
  • Centrally managed costs, such as employee benefit plans; and
  • Services provided by other departments, such as office accommodations.

To capture these elements and calculate full cost, TC applied a costing model that follows principles of activity-based costing to assign costs to all Marine Safety services and activities based on their use of resources. Four years of actual expenditure and full-time equivalent (FTE) details were extracted from departmental financial systems, and data on time-tracked hours was sourced from TC's internal tracking system.

The Marine Safety cost recovery costing model captures historical Marine Safety costs. For the Program, these costs have been incurred pursuant to three regulations, the PWR, the CFTR and the BSISF (see Section 5.2 above). The Program is well-established and expected to remain resourced at stable levels in the foreseeable future. Thus, it is appropriate to use historical cost analysis to inform the ongoing cost of the Program and its activities for fee-setting purposes. Based on the results of the program cost analysis, the annual, ongoing full cost for the Program is $7.6M.

6.1.1 Marine Cargo Inspections

Marine cargo inspections are conducted to verify the safe loading and stowing of higher risk cargos, namely grain, timber on deck and concentrates. The nature of the industry requires these inspections to be carried out 24 hours a day, seven days a week.

The average number of annual hours, which includes time spent on ship, overtime, travelling, and in the office, required to provide inspection services is used as the basis to apportion the full cost of the Program to each cargo inspection activity (i.e. regulated cargo inspections), and the much-less-frequent dangerous goods inspections and verification of shippers' procedures.

Once the full cost of the program was apportioned to each inspection activity, the annual cost of grain, timber on deck, and concentrates inspections was divided by the annual number of vessels inspected to determine the full cost. At an aggregate level (for all regulated cargo types combined), the average full cost to complete the inspections is $5,039. Based on the previous four fiscal years, the average annual departmental cost of inspection of marine cargoes is $7,598,756.

6.1.2 Inspection of Bulk and/or Packaged Dangerous Goods

The inspection of dangerous goods is done upon request of an” interested person” (as described in section 1.2 above). Fees are charged when an inspection is made pursuant to a request from an “interested person” to inspect vessels on which dangerous goods in solid bulk and/or packaged form are loaded, carried or unloaded.

Dangerous goods inspections at the request of an “interested person” occur infrequently, as mentioned above. The average cost of a Dangerous Goods (bulk or packaged) inspection is $2,891. Based on the previous four fiscal years, the average annual departmental cost of Inspection of Dangerous Goods is $20,234.

6.1.3 Verification of Shippers' Procedures

Shippers' Procedures verifications require on-site visits to shipper facilities and TC office time. As these services are typically carried out during normal working hours, the cost for the activity is adjusted to remove overtime.

To develop cost estimates for the Initial, Intermediate, Renewal, and Modification verifications, TC relied on information from TC's database and on subject matter experts' knowledge. The most time consuming activity, Initial Verifications, cost approximately $3,338, while the least intensive activity, Renewal Verifications, cost $1,669. Based on the previous four fiscal years, the average annual departmental cost of Verification of Shippers' Procedures is $30,024.

7.0. Proposed New Fee Levels

7.1. Establishing Revised Fee Levels (Price)

In order to arrive at the proposed fees for marine cargo inspections, inspections at the request of an “interested person” for dangerous goods, and verification of shippers' procedures, TC applied a series of analytical lenses to determine how to refine the full cost of these services. These analytical lenses:

  • Assessed the services to determine how much of the benefits accrued to private companies or individuals, as opposed to the Canadian public generally;
  • Examined comparable jurisdictions to see what, if any, fees were charged for similar services by national authorities; and
  • Examined the economic context in which the Canadian marine cargo industry operates to assess the impact rising fees would have on stakeholders and considered other factors that may impact members of the industry and therefore the ability of stakeholders to bear higher fees.

By utilizing these lenses, TC determined that setting fee levels at a rate that would recover 100 percent of its costs was not appropriate. The information considered as part of each lens, and the impact these lenses had on the proposed fees are described in greater detail below.

7.2. Applying the Analytical Lenses

7.2.1. Public-Private Assessment

Determining what proportion of a service constitutes public and private benefit is fundamental to initial decisions regarding which services should be subject to fees and what the cost recovery rate (the percentage of the costs paid by the user) should be for these services.

TC provides many services that offer neither purely public nor purely private benefits and must therefore consider this proportion when setting cost recovery rates. While services that convey purely public or private benefit have obvious cost recovery rates (0 percent and 100 percent, respectively), setting the cost recovery rate for a service that provides a mix of private and public benefits requires complex considerations.

A Public-Private Assessment (PPA) was conducted using the PPA tool developed by the Treasury Board Secretariat (TBS). The PPA tool estimates the degree to which a service provides a private benefit, if any, above and beyond benefits enjoyed by the general public. The PPA tool estimated that the services provided by the marine cargo program are essentially a private good. It calculated that 90 percent of the benefits from the marine cargo program accrue to private companies or individuals, rather than to Canadians more broadly.

7.2.2. International Comparisons

Canada is a major exporter of bulk cargo. Inspections, which are based on international standards, are necessary to ensure the stability and structural integrity of vessels traveling in Canadian waters, as well as ensuring the safety of personnel on board.

Other jurisdictions have adopted a variety of approaches to cost recovery related to marine cargo. Like Canada, most of the jurisdictions reviewed have adopted a mixture of fixed and hourly rates for such services. Table 1 below summarizes the hourly rates applied by other jurisdictions.

Table 1 - Hourly Fees in Foreign Jurisdictions:

Foreign Jurisdiction

Foreign Fee
(Foreign Currency)

Foreign Fee
(Canadian $ Equivalent)

* Rates taken from http://www.xe.com/ as of November 9th, 2018

* Figures have been rounded to the nearest dollar.

Australia

$272 AUD / hour

$261 CAD / hour

United States

$108-$160 USD / hour

$142-$210 CAD / hour

Rates in Australia are two times higher than the current rates charged in Canada. The National Cargo Bureau in the United States charges rates one to five times higher than those in Canada.

An interesting comparison is that of grain inspection in the US and Canada:

  • In Canada, a flat fee of $135 is charged per visit for the survey of the condition of any ship before the loading of cargo.
  • In the US for the same service, $776 CAD is charged for the first 1,000 tonnes and $59 CAD for every additional 1,000 metric tons.

The minimum US fee compared to Canada is 5.75 times higher ($135 minimum charged in Canada compared to a $776 minimum charged in the US).

Refer to Appendix A for more international comparison details.

7.2.3. Stakeholder Impact Analysis

Canadian natural products, such as wood products, grain and concentrates, rely primarily on foreign-based carrier companies to export marine cargo. Pursuant to the CFTR, fees under the marine cargo program only apply to regulated cargoes bound for export and not to Canadian vessels operating domestically (i.e. no fees apply to ships travelling within Canada).

The economic context in which members of this industry operate is an important analytical lens in terms of proposing revised fees. The goal of TC's Fee Modernization initiative is to have those who benefit the most from services pay a greater share of the costs. This goal must be balanced with TC's role as a regulator and economic enabler. The fees proposed herein were developed within the context of the relative economic health of the industry, and are designed to align with the ability of industry members to pay higher fees.

While stakeholders may experience a modest rise in fees, this is partially mitigated by the simplification of the fee structure. Both preliminary and targeted consultations revealed that, in most cases, stakeholders are amenable to fee increases and support a new fee structure, as long as services continue to be provided in a timely manner. For these stakeholders, the expeditious movement of cargo with minimal delays is of the utmost importance.

Stakeholder Profile

The marine sector transports bulk and containerized cargo domestically and overseas. Over the 2006–2015 period, Canada's international marine trade totalled $1.9 trillion (Statistics Canada, 2015Footnote 1). The majority of marine exports are bulk commodities. By tonnes, the top marine export in 2011 was coal, followed by iron ore, crude oil, wheat, and fuel oil. By dollar value, the largest marine exports over the 2006–2015 period were oil and coal with a value of $254 billion. Iron ore, wheat, canola, and nickel are also important marine export commodities (Statistics Canada, 2015). However, Canadian shippers rely predominantly on foreign registered fleets to carry goods to non US international destinations. A number of Canadian-based marine companies active in international trade use foreign registered vessels. The main ones are Fednav Ltd., CSL International (Canada Steamship Lines), Canfornav and Kent Line.

Canadian registered vessels play an important role in Canada's domestic trade and is the mode of transportation for many important bulk commodity movements, including the grain, iron ore and coal transported between Great Lakes ports; the crude oil shipped from the Terra Nova oil field off Newfoundland's coast; and forest products shipped from northern to southern B.C. portsFootnote 2.

The marine cargo industry also supports Northern resupply and resource development, passenger coastal and inland ferry services. Ferries in Canada provide an important transportation link for coastal and island communities, as well as communities separated by a river or lake where crossing demands do not warrant building a bridge. Ferries also play a vital role in resupplying some communities across the country. The members of the Canadian Ferry Association, which includes all major ferry routes in Canada, carried more than 55 million passengers and more than 19 million vehicles in 2015.Footnote 3

Impact on the Industry

Considering the value of the commodities being shipped and the overall economic health of the industry, TC does not expect that increased fees would have a significant impact on stakeholders. In fact, preliminary and targeted consultations consistently demonstrated that stakeholders were neutral with respect to the proposed new fees. Their primary concern was centred on continuing to receive timely service from TC.

7.3. Proposed Fixed Fees

Considering the factors described above, TC is proposing new fixed fees that better reflect the costs to TC in delivering the services. The new fees align with the user-pay principle given that the benefits accrue primarily to the service recipients.

7.3.1 Marine Cargo Inspections

The average cost to complete an inspection is $5,039. TC is proposing a daily fee per service carried out by the Program. The new fee structure would reduce the number of fees from forty (refer to Appendix C) to two:

  1. Certificate Day Fee ($1,900)
    • One daily fee per calendar day, per vessel, that a certificate is issued (i.e. readiness to load (RTL), fitness to proceed (FTP), and/or preliminary certificates).
  2. Non-Certificate Day Fee ($512)
    • One daily fee per calendar day, per vessel, that an inspector is requested to be available. No certificate is issued on that calendar day, but an inspector is available or is available and makes an inspection.

These daily fees:

  • include overtime and travel costs, so there will be no separate charges for those items;
  • have no separate fee per certificate when issued; and
  • have no separate fee for amounts of cargo (tonnage loaded), regardless of type;

It should also be noted that:

  • if more than one certificate is issued on the same calendar day, TC will only charge one Certificate Day Fee; and
  • if two inspectors are requested to be available for the same vessel on a calendar day, TC will charge two Non-Certificate Day fees.

These daily fees are expected to yield an average cost recovery rate of 91 percent for Marine Cargo inspection services. This new fee design is a significant simplification over the current outdated and overly prescriptive fee design and will provide cost predictability.

7.3.2 Inspection of Bulk and/or Packaged Dangerous Goods

As mentioned above, a fee is levied when an inspection is made pursuant to a request from an “interested person” to inspect a vessel on which dangerous goods in solid bulk and/or packaged form are loaded, carried or unloaded.

In the last three years, TC conducted 21 inspections under the scenario described above.

It is proposed that a fixed fee of $1,500 be charged for each inspection of Bulk and/or Packaged Dangerous Goods requested by an “interested person”. This fee would establish a cost recovery rate for Inspection of Bulk and/or Packaged Dangerous Goods of 52 percent from the current cost recovery rate of seven percent.

7.3.3 Verification of Shippers' Procedures

As previously mentioned, verification of shippers' procedures require on-site visits to shipper facilities and TC office time. In the last three fiscal years, from 2015-2016 to 2017-2018, the Verifications of Shippers' Procedures has declined from twenty verification letters to nine letters respectively. The number of verifications and the amount of time spent on this activity is expected to decline in future years, due to the inspectors' increased level of familiarity in providing this service. The average cost of verification of shippers' procedures ranges from $1,669 to $3,338, depending on the level of effort and complexity of the verification being conducted.

It is proposed that the fee structure for this service be similar in design to the rest of the program (i.e. two-tiered structure). One tier for Initial and Modifications verifications and another tier for Intermediate and Renewal verifications. These four activities have been grouped in these two categories due to their similar levels of effort. A fixed fee of $2,500 for Initial or Modifications verifications, and a separate fixed fee $1,250 for Intermediate or Renewal verifications is proposed to be charged. These two fees would establish a cost recovery rate for the verification of shippers' procedures of 75 percent, from the current cost recovery rate of zero percent.

7.4. Conclusion

TC has considered the factors described above in order to establish new fees for the Program. TC is proposing fees that reflect the costs of providing these services as well as the benefits that accrue to the service recipients, aiming to align more with the user-pay principle.

Given both the volume and value of commodities inspected by the marine cargo program and the complexity of the current fee structure, the proposed new fee design provides simplification and cost predictability to stakeholders while also addressing TC's need for a sustainable revenue model to continue providing timely services.

TC believes that the proposed fees offer a balanced approach without compromising the economic health of the Canadian marine industry.

8.0. Proposed Regulatory Amendments

As part of its ongoing Fee Modernization initiative, TC is considering consolidating all marine safety fees charged pursuant to the Canada Shipping Act, 2001 into one new regulation. This new marine safety fee regulation would be the sole location for all of the new and amended fees for marine cargo services. Consequential amendments to existing fee regulations would be put forward to repeal references to the old marine cargo fees. For example, all the new and revised marine cargo fees would be entered into this new marine fee regulation. The existing marine cargo fees contained in the CFTR, the PWT and the BSISF (see Section 5.2 above) would no longer be required in these various regulations and would be repealed.

This fee regulation consolidation would allow stakeholders to view almost all marine-related fees under one regulation, thereby greatly simplifying the regulatory fee framework for stakeholders and minimizing confusion and uncertainty around TC's fees for marine services.

9.0. Service Standards

Previous in-person and online consultations and surveys have shown that the stakeholders are generally satisfied with the overall level of service provided. However, stakeholders have repeatedly stressed that the availability of inspectors and the timeliness of inspections are imperative due to the time sensitivity of the industry. Delays in shipping of cargo could result in significant losses of revenue of the stakeholders. The current service standards may be found at: https://www.tc.gc.ca/eng/marinesafety/service-standards-cargo-control-4332.html

The proposed service standards and their related services are summarized below:

Services and Fees

Proposed Service Standards

1.

Certificate Day Fee (for Cargo Inspections):

One daily fee per calendar day, per vessel, that a certificate is issued (i.e. readiness to load (RTL), fitness to proceed (FTP), and/or preliminary certificates).

Issue certificate and/or transcript, as applicable, within 24 hours after boarding the vessel.

2.

Non-Certificate Day Fee (For Cargo Inspections):

One daily fee per calendar day, per vessel, that an inspector is requested to be available. No certificate is issued on that calendar day, but an inspector is available or is available and makes an inspection.

Assign an inspector and provide an agreed upon date for onsite vessel appointment, within 24 hours of receiving a request for an inspector to be available.

3.

Inspection of Bulk and/or Packaged Dangerous Goods Fee:

Request for an inspection, by an “interested person”, to inspect a vessel on which dangerous goods in solid bulk and/or packaged form are loaded, carried or unloaded, under the CFTR.

Assign an inspector and provide an agreed upon date for onsite inspection, within 24 hours of receiving a request for an inspector to be available.

4.

Verification of Shippers' Procedures Fees: Initial and Modifications verifications & Intermediate and Renewal verifications.

Issue a letter of approval within 5 working days after satisfactory completion of verification.

9.1. Effective Date of Proposed Service Standard

The proposed service standards will be implemented at the same time as the new fees come into force following Governor in Council approval.

9.2. Remission Policy

The Service Fees Act (SFA) requires government departments to remit a portion of a fee when the department determines that a service standard associated with a fee has not been met. Guidance concerning the SFA from the Treasury Board of Canada Secretariat (TBS) further requires departments to develop and publish a Remission Policy outlining the circumstances under which fees will be remitted. TC's Remission Policy is currently under development and will be in place prior to the introduction of marine cargo fees. Remissions will take place in accordance with TC's Remission Policy and the TBS Directive on Charging and Special Financial Authorities.

10.0. Implementation

TC will develop guidance and explanatory materials for both the program and the industry to ensure that the new fees are applied consistently across Canada, and to ensure that stakeholders can clearly understand how and when the fees will be applied and what their responsibilities and liabilities will be under the revised regulations. These materials will be developed based in part on feedback received from stakeholders in response to this Marine Cargo Fee Modernization Proposal as well as throughout the regulatory process necessary to amend the regulations. These materials will be ready before the new fees comes into force.

In accordance with the Service Fees Act, the proposed fees will be indexed annually, based on the applicable Consumer Price Index published by Statistics Canada. The inflation-adjusted fee levels and the date they will come into effect will be published in TC's Annual Fees Report tabled in Parliament and will be made available on the TC website.

11.0. Stakeholder Consultations

TC has engaged with the industry to seek preliminary feedback concerning fee modernization for the marine cargo program.

Presentations were made to raise awareness and seek input from industry members at the regional and national plenary sessions of the Canadian Marine Advisory Council (CMAC) meetings held between December 2017 and May 2018. These presentations outlined the goals and timeframes associated with this initiative. Stakeholders were provided the opportunity to ask questions and provide input.

More detailed stakeholder engagement sessions were held with stakeholders from the marine industry on June 11, 2018 and June 20, 2018 in Montreal and Vancouver, respectively.

TC solicited preliminary feedback on the following topics:

  • Introduction of non-certificate and certificate day fees;
  • Elimination of the stand-by fee in its current form;
  • Pricing ranges under consideration; and
  • Service standards under consideration.

During these engagement sessions, participants supported the proposed simplified fee structure and called for opportunities to explore how some of the services provided could be streamlined and more cost effective. Stakeholders also expressed a desire to receive advance notice prior to the implementation of the new cost recovery regime.

At the November 2018 CMAC, TC provided an update on the status of the Marine Cargo fee proposal to stakeholders. Only one question was raised during that presentation, specific to the definition and treatment of the term “interested person” with respect to the Dangerous Goods inspections. TC acknowledged the issue and committed to remove any ambiguity surrounding the use and interpretation of that term through the regulatory process associated with this fee modernization initiative.

TC intends to continue to engage with stakeholders to seek their input on this fee proposal. These views will be taken into account and will be reflected in the Regulatory Impact Analysis Statement that will be published with the proposed regulations in the Canada Gazette, Part I.

Appendix A: International Benchmarking

The certification process and related fees charged in Australia and the US were used as comparators in the development of this Fee Proposal and are described in detail below.

Table 2: Transport Canada's Proposed Fees Compared to Other Jurisdictions

Service

Fees

United States

Australia

Grain Inspection

Readiness to Load

Issuance of Certificate of Readiness to Load and Certificate of Loading after completion:

  • First 1000 tons - $600 US ($781 CAD); and
  • Each additional 1,000 tons or any part thereof - $46 US ($60 CAD)

Note: First 1,000 metric tons plus additional tonnage fee is subject to a $1,400 US ($1,823 CAD) minimum.

  • Each tween deck, wing, side compartment or deep tank - $46 US ($60 CAD) per compartment;
  • Reviewing Stability of a $108 US ($141 CAD) per hour vessel (4-hour minimum).

Visits to vessels or loading facilities for inspections to ensure safe loading and stowage of grain:

  • $272 AUS ($260 CAD) per hour plus travel and other expenses.

Inspection During Loading

Fitness to Proceed

Timber Deck Inspection

Readiness to Load

No fee specified. Attendance on vessels loading timber on deck is not mandatory.

*Specific service not itemized in the AMSA fee schedule; however, likely that the hourly fee applies:

  • $272 AUS ($260 CAD) per hour plus travel and other expenses.

Inspection During Loading

Fitness to Proceed

Concentrates Inspection

Readiness to Load

No fee specified. Attendance on vessels loading concentrates is not mandatory.

*Specific service not itemized in the AMSA fee schedule; however, likely that the hourly fee applies:

  • $272 AUS ($260 CAD) per hour plus travel and other expenses.

Inspection During Loading

Fitness to Proceed

Dangerous Goods (Bulk and/or Packaged Goods)

Ship Inspection

No fee specified. Inspection of dangerous goods shipments is not mandatory.

Inspections, determinations, approvals and exemptions for dangerous goods/solid bulk cargoes:

  • $272 AUS ($260 CAD) per hour plus travel and other expenses.

Loading Plan Approval

Container Inspection

Approvals

Shippers' Approval (Solid Bulk Cargoes)

No fee specified.

*Specific service not itemized in the AMSA fee schedule; however, likely that the hourly fee applies:

  • $272 AUS ($260 CAD) per hour plus travel and other expenses.

Reservation, Dispatch and Tracking

Base Service

Additional fees:

  • $108 US ($141 CAD) per hour (for waiting time, special services, extra visits at request) Transportation, travel (accommodation) and overtime fees are also payable.
  • $AUS 272 ($260 CAD) per hour for waiting time plus travel and other expenses.

* TC is consulting with the Australian Maritime Safety Authority (AMSA) to verify fees for similar marine cargo services.

Australia

When AMSA was established under the Australian Maritime Safety Authority Act 1990, the Government's intent was ‘that the Authority will run its commercial services on a self-funded basis; services which cannot be provided on a self-funded basis (such as search and rescue) will be paid for by the Commonwealth'.

The Explanatory Memorandum further states that ‘as well as receiving revenue by way of fees for specific services provided to individual ship owners, the Authority will need to receive the revenue from the more general marine navigation levy and the oil pollution fund levy' (clause 48 – Payment of amounts of levy to Authority).

The majority of AMSA's services fees are charged at an hourly rate. The hourly rate for services provided by an inspector or equivalent AMSA officer is:

(a) $272 for each hour, calculated for each half hour or remaining part of a half hour; or

(b) for a service that takes less than 30 minutes — the fixed amount of $136.

The charge payable for an officer who travels to perform a service at a location other than where the officer is normally stationed is the sum of:

  • The hourly rate for the time taken for travelling (including any travel to and from a vessel that is not alongside a berth),
  • The costs AMSA reasonably incurs for the travel; and
  • For travel more than 25 km from an AMSA office — the charge per kilometre specified for the financial year by the Australian Taxation Office for business use of the vehicle used (64 cents CAD per kilometre).

United States of America

The National Cargo Bureau was incorporated as a non-profit organization in 1952. The Bureau was created to render assistance to the United States Coast Guard in discharging its responsibilities.

Under the authority of the United States Coast Guard, the certificates issued by National Cargo Bureau may be accepted as evidence of compliance with the provisions of the Dangerous Cargo Act and the Rules and Regulations for Bulk Grain Cargo. The Bureau offers several services including grain vessel surveys, bulk cargo vessel surveys, container/cargo inspections, claims and loss prevention and flag state inspections.

Case Study: Service Request to Load Grain – International Comparison

This portion of the Marine Cargo Fee Modernization Proposal provides an example of a real grain service request and how the fees vary between our current design, our proposed design and the design of the US and Australia.

The case study examines a service request wherein inspectors spent 29.5 hours inspecting 33,000 tons of grain over a five day period.

Charges for the services rendered and their comparisons to the proposed fee design between Canada, the US and Australia are illustrated by Table 5. All amounts listed in the table are in Canadian dollars.

Table 5: Fee Comparison Example

Service

Current Fee Design

Proposed Fee Design

USA

Australia

Preliminary Certificate

$135

$1,900

-

-

Certificate of Readiness to load grain

$135

$1,900

$2,700

-

Grain survey max fee + FTP Certificate

$957

$1,900

-

-

Visits between 5:00pm and 8:00am, Mon-Fri

$420

-

$524

$7,699

Visits between 5:00pm and 8:00am, Mon-Fri

$140

-

$175

-

Visits, Sunday

$891

-

$786

-

TOTAL

$2,678

$5,700

$4,185

$7,699

Appendix B – Applicable Statutory Framework

Cargo, Fumigation and Tackle Regulations

http://laws-lois.justice.gc.ca/eng/regulations/SOR-2007-128/index.html

Part I Division 2 Solid Bulk Cargo Other Than Grain

Documentation

(Note – BC Code has been replaced by the IMSBC Code)

  • 115 (1) Every shipper of solid bulk cargo to be loaded onto a vessel in Canadian waters shall comply with:
    • (b) section 4 of the BC Code;

Dangerous Goods

Dangerous Goods and Packaged Goods

113 If dangerous goods are to be carried with packaged goods, the person in charge of loading the goods shall ensure that they are segregated in accordance with the BC Code.

Inspection at the Request of an “Interested Person”

116 (1) A marine safety inspector authorized by the Minister under subsection 11(2) of the Act to carry out inspections to ensure compliance with sections 110 to 115 shall carry out an inspection of a vessel on which dangerous goods are loaded, carried or unloaded to ensure compliance with sections 110 to 115 if an “interested person” makes a request to the Department of Transport Marine Safety Office nearest to the vessel.

Concentrates

Certificate of Readiness to Load

119 (2) No vessel in Canadian Waters shall load concentrates except in accordance with a Certificate of Readiness to Load issued to the vessel by the Minister, or in the Port of Quebec, by the Port Warden of the Harbor of Quebec.

119 (5) If the Minister inspects a vessel for the purpose of establishing whether the requirements for the issuance of Certificate of Readiness to Load have been met and establishes that some requirements have not been met, he or she shall give the vessel's master a written statement setting out those requirements.

Fitness to Proceed Certificates

120 (1) No vessel that is carrying concentrates for export to a place that is not within the limits of an inland voyage shall depart from a Canadian port unless it holds a Fitness to Proceed Certificate issued under subsection (2).

Part I Division 3 Grain Cargo

Certificate of Readiness to Load

128 (1) No vessel in Canadian Waters shall load grain except in accordance with a Certificate of Readiness to Load issued to the vessel by the Minister, or in the Port of Quebec, by the Port Warden of the Harbor of Quebec.

128 (4) If the Minister inspects a vessel for the purpose of establishing whether the requirements for the issuance of Certificate of Readiness to Load have been met and establishes that some requirements have not been met, he or she shall give the vessel's master a written statement setting out those requirements.

Fitness to Proceed Certificates

129 (1) No vessel that is carrying grain for export to a place that is not within the limits of an inland voyage shall depart from a Canadian port unless it holds a Fitness to Proceed Certificate issued under subsection (2).

Part I Division 4 Timber Deck Cargo

Certificate of readiness to Load

140 (2) No vessel in Canadian Waters shall load timber except in accordance with a Certificate of Readiness to Load issued to the vessel by the Minister, or in the Port of Quebec, by the Port Warden of the Harbor of Quebec.

140 (5) If the Minister inspects a vessel for the purpose of establishing whether the requirements for the issuance of Certificate of Readiness to Load have been met and establishes that some requirements have not been met, he or she shall give the vessel's master a written statement setting out those requirements.

Fitness to Proceed Certificates

141 (1) No vessel that is carrying timber for export to a place that is not within the limits of an inland voyage shall depart from a Canadian port unless it holds a Fitness to Proceed Certificate issued under subsection (2).

Part I Division 5 Packaged Goods

Inspection at the Request of an “Interested Person”

162 (1) A marine safety inspector authorized by the Minister under subsection 11(2) of the Act to carry out inspections to ensure compliance with this Division shall carry out an inspection of a vessel on which dangerous goods are loaded, carried or unloaded to ensure compliance with this Division if an “interested person” makes a request to the Department of Transport Marine Safety Office nearest to the vessel.

Port Wardens Tariff

http://laws-lois.justice.gc.ca/eng/regulations/SOR-79-154/index.html.

Fees

4 The master or owner of a ship in respect of which a port warden has performed a service described in column I of an item of the schedule shall pay to the port warden the fee set out in Column II of that item.

Board of Steamship Inspection Scale of Fees

http://laws-lois.justice.gc.ca/eng/regulations/C.R.C.,_c._1405/FullText.html?wbdisable=false.

Out-of-Hours Duties

28 The fee payable for each visit for the purpose of a survey or inspection of a ship by an inspector, or a service performed by an inspector, at the request of a shipyard operator, shipowner or ship operator, or authorized representative thereof, including the traveling time related to the visit, that is conducted during the hours set out in column I of an item of the table to this section is, in addition to any other fee payable, the greater of the fees set out in columns II and III of the item.

Standby Fee for Inspectors

29 Where a shipyard operator, shipowner or ship operator, or an authorized representative thereof, requests that an inspector be on call or be made available, either continuously or during specified periods, to survey or inspect a ship or to perform a service, a standby fee of $500 is payable, in addition to all other fees payable, for each calendar day or portion thereof that the inspector is on call or made available.

Appendix C: Detailed List of Current Fees and Service Standards

Note – currently, there are no fees or service standards for Verification of Shippers' Procedures.

Marine Cargo Inspections

Port Wardens Tariff

Item

Description of Service

Fee

Service Standards

1

Survey of the opening of the hatches of any ship.

$135 per visit

Issue certificate and/or transcript, as applicable, within 5 working days after completion of satisfactory inspection.

2

Memorandum relating to the condition of the hatches opened in the presence of the port warden.

$88

Issue certificate and/or transcript, as applicable, within 5 working days after completion of satisfactory inspection.

3

Examination of the condition and stowage of cargo on board any ship or examination of any merchandise, vessel, material, produce or other property.

$0.069/tonne $135 min $957 max

Issue a transcript after satisfactory inspection is complete – within 5 working days of boarding.

4

Original memorandum relating to an inquiry, examination and ascertainment of the cause of damage to goods or relating to any merchandise, vessel, material, produce or other property.

$88

Issue certificate and/or transcript, as applicable, within 5 working days after completion of satisfactory inspection.

Dispute

5

Hearing and arbitration on any difficulty or matter in dispute.

$45 per hour or part thereof

Process request for hearing or arbitration of difficulty or matter in dispute by assigning an inspector within 3 working days of complaint being filed.

Grain Surveys

6

Survey of the condition of any ship before the loading of cargo and any statement made.

$135 per visit

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

7

Survey of one or more chambers or compartments in any ship and issuance of a certificate of readiness to load.

$135 per visit

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

8

Examination at a port of the state of fitness of a ship that has been laden with grain at that port and issuance of a certificate of fitness to proceed to sea.

$0.069/tonne $233 min $957 max

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

9

Examination at a port of the state of fitness of a ship, where the ship has not been laden with bulk grain at that port but is carrying a cargo of bulk grain that was loaded at another port and subsequently overstowed with other cargo and issuance of a certificate of fitness to proceed to sea.

$233

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

10

Examination at a port of the state of fitness of a ship in transit that has at another port been laden with grain, examined as to its state of fitness and issued a certificate and issuance of a further certificate of fitness to proceed to sea.

$135

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

11

For a survey or examination described in item 6, 7 or 8 of a tanker loading grain or a bulk carrier loading grain in wing tanks, in addition to the fee set out in item 6, 7 or 8.

$40 per tank surveyed

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

Timber Deck Cargo Surveys

12

Supervision of the loading of a timber deck cargo.

$0.069/tonne $135 min $957 max

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

12.1

Issuance of a certificate in relation to timber deck cargoes.

$135

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

13

Examination at a port of the state of fitness of a ship that has been laden with a timber deck cargo at that port and issuance of a certificate of fitness to proceed to sea.

$233 per visit

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

14

Examination at a port of the state of fitness of a ship in transit that has at another port been laden with a timber deck cargo, examined as to its state of fitness and issued a certificate, and issuance of a further certificate of fitness to proceed to sea.

$135 per visit

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

Concentrate Surveys

15

Survey of the stowage of concentrates on board a ship.

$0.069/tonne $233 min $957 max

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

15.1

Certificate of approval of the stowage of concentrates on board a ship.

$135

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

16

Examination at a port of the state of fitness of a ship that has been laden with concentrates at that port and issuance of a certificate of fitness to proceed to sea.

$135 per visit

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

17

Examination at a port of the state of fitness of a ship in transit that has at another port been laden with concentrates, examined as to its state of fitness and issued a certificate, and issuance of a further certificate of fitness to proceed to sea.

$135 per visit

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

Dunnage and Separation

18

Determination of necessary dunnage and separations between cargoes or part cargoes and issuance of a certificate.

$51 per hold

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

19

Examination of the amount of cargo carried by a ship or inspection of a ship to determine the existence of overloading or improper loading.

$88

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

General

20

For certificates in writing, under the hand of the port warden, of any matters of record in the port warden's office.

$40

per certificate

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

21

For copies of any records or entries in the port warden's books or documents filed in the port warden's office.

$15 per copy

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

Additional Fees

22

Surveys, inspections or examinations, between 5:00pm and 8:00am, Monday to Friday other than on a holiday, in addition to any other prescribed fee

  • Per hour or part of an hour, including travelling time;
  • Minimum fee payable.
  • $70
  • $140

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

23

Surveys, inspections or examinations, Saturdays or holidays, in addition to any other prescribed fee

  • Per hour or part of an hour, including travelling time;
  • Minimum fee payable.
  • $70
  • $210

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

24

Surveys, inspections or examinations, Sundays, in addition to any other prescribed fee

  • Per hour or part of an hour, including travelling time;
  • Minimum fee payable.
  • $99
  • $297

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

25

For any service rendered at a place more than 16 km from the port warden's office, or at a vessel anchorage, between 8:00am and 5:00pm, Monday to Friday other than on a holiday, for each hour or part of an hour engaged in travel, in addition to any other prescribed fee.

$45

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

26

For any service rendered at a place more than 16 km from the port warden's office.

Total of all actual travelling, lodging and meal expenditures.

Issue certificate and/or transcript, as applicable, within 24 hours of boarding vessel.

Inspection of Bulk and Packaged Dangerous Goods

Cargo, Fumigation and Tackle Regualtions

Item

Description of Service

Fee

Service Standards

Division 2 – Dangerous Goods (Solid Bulk Cargo, other than grain)

Inspection at the request of an interested person section 116 (3) for solid cargo, other than grain, carried in bulk

1

Between 8:00 a.m. and 5:00 p.m., Monday to Friday, other than on a holiday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $45
  • $45

Issue certificate and/or transcript, as applicable, within 5 working days after completion of satisfactory inspection.

2

Between 5:00 p.m. and 8:00 a.m., Monday to Friday, other than on a holiday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $70
  • $140

3

Any hour on a Sunday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $99
  • $297

4

Other hours

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $70
  • $210

Division 5 – Packaged Goods (Explosives, Ammonium Nitrate and Ammonium Nitrate Fertilizer)

Inspection at the request of an interested person section 162(3) for cargo carried in Packaged Goods

1

Between 8:00 a.m. and 5:00 p.m., Monday to Friday, other than on a holiday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $45
  • $45

Issue certificate and/or transcript, as applicable, within 5 working days after completion of satisfactory inspection.

2

Between 5:00 p.m. and 8:00 a.m., Monday to Friday, other than on a holiday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $70
  • $140

Cargo, Fumigation and Tackle Regualtions

Item

Description of Service

Fee

Service Standards

3

Any hour on a Sunday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $99
  • $297

Issue certificate and/or transcript, as applicable, within 5 working days after completion of satisfactory inspection.

4

Other hours

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $70
  • $210
Applicable to all Inspections

Board of Steampship Scale of Fees

Item

Description of Service

Fee

Service Standards

28 Out-of-Hours Duties

1

Between 5:00 p.m. and 8:00 a.m., Monday to Friday, other than on a holiday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $70
  • $140

N/A

2

Any hour on a Saturday or holiday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $70
  • $210

3

Any hour on a Sunday

  • Fee per hour or fraction of an hour ($);
  • Minimum fee.
  • $99
  • $297

Standby Fee for Inspectors

29

Standby Fee for Inspectors

(fee applies to each calendar day and resets at midnight).

$500

N/A

Date modified: