2015 
Carrier Liability 
213 
is unwilling or unable to exert the necessary legal pressure 
on ship operators. Overcrowded ferries might become a 
thing of the past if the insurance costs significantly exceed 
the potential profits. Such an indirect regulatory effect is 
certainly far from perfect, but it could help in instances 
where there is even less of a direct (domestic) regulatory 
effect. In so far, the EU's Passenger Liability Regulation can 
provide an inspiration for other states to ratify and 
implement the Athens Convention in its revised form. 
Unfortunately, doing so will not necessarily solve the 
problem that is more urgent in the developing world than in 
the EU: domestic voyages. Although EU member states are 
given the option to pass the PLR right away, the EU delayed 
the applicability of the PLR to domestic voyages for four 
years after the entry into force of the PLR 74 and in some 
cases even until December 31, 2018. 75 Often it is domestic 
voyages in developing nations that lead to the loss of human 
lives in large numbers. 76 The aforementioned Rabaul Queen, 
Shariatpur 1, and Costa Concordia incidents are only three in a 
long line of disasters that have claimed the lives of 
passengers at sea. In 2015, the IMO adopted guidelines to 
improve safety in domestic ferry operations. 77 
74 PLR at art. 11(1). 
75 PLR at Annex I, art. 11(2). 
76 For more detail, see e.g. Aleik Nurwahyudy, Contemporary issues in 
domestic ro-ro passenger ferry operation in developing countries: identification 
of safety issues in domestic ferry operation based on accident investigation 
reports on ferry involved accidents in Indonesian waters, 2003 - 2013, World 
Maritime University Dissertations, Paper 463 (2014). 
77 Rebecca Gibson, IMO adopts new guidelines to improve domestic ferry 
safety, Cruise & Ferry (Apr. 28, 2015), 
http://www.cruiseandferry.net/articles/imo-adopts-new-guidelines-to- 
improve-domestic-ferry-safety#.Vkbs7K4rK5w.