Members are advised that from 1 October 2020, IMO adopted amendments to MARPOL Annexes I, II, V, VI and the NOx Technical Code will enter into force, enabling the use of Electronic Record Books (ERBs) in lieu of paper record books.
An ERB could be a device, system or software application designed to facilitate accurate entries for discharges, transfers, and other operations into an efficient electronic format, while complying with International Conventions and Flag State requirements.With these amendments in force, it is expected that the burden associated with paperwork will be reduced.
The IMO guidelines apply to the use of electronic record books on board to meet the requirements of the following record books:
- Oil Record Book, parts I and II (MARPOL Annex I, regulations 17.1 and 36.1)
- Cargo Record Book (MARPOL Annex II, regulation 15.1)
- Garbage Record Book, parts I and II (MARPOL Annex V, regulation 10.3)
- Ozone-depleting Substances (ODS) Record Book (MARPOL Annex VI, regulation 12.6)
- Recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI, regulation 13.5.3)
- Record of Fuel Oil Changeover (MARPOL Annex VI, regulation 14.6)
- Record Book of Engine Parameters (NOX Technical Code, paragraph 22.214.171.124)
Guidelines for the use of electronic record books are provided in the attached IMO Resolution MEPC.312(74). Details of the amendments are provided in the attached IMO Resolutions MEPC.314(74), MEPC.316(74), and MEPC.317(74).
When the ERB is proposed to be used on board a ship as an alternative to the official hard copy record book, the Flag State has to assess and issue a 'Declaration of MARPOL Electronic Record Book(s)'. This declaration must be kept on board for presentation to authorised officials when requested. The procedures related to the use of ERBs must be documented in the Safety Management System (SMS).
With regards to PSC inspections of electronic records, MEPC.312(74) states that
'It is recommended that if a ship cannot produce the electronic record book or a declaration provided by the Administration during the PSC inspection, the PSC officer should request to view an alternative verified copy of the records or a hard copy record book for verification'.
To comply with MARPOL requirements, an ERB should have the capability to retain all records made for the minimum period as specified in each Annex of MARPOL. The capability to produce a hard copy of verified records for the master to certify as a true copy, upon request from relevant authorities, should also be provided.
It is essential to understand that the use of MARPOL ERBs or other electronic logbook systems does not lessen member’s responsibility to accurately record, maintain, and produce records during an inspection per international requirements. As such, it is recommended that all shipboard records and logs are maintained accurately and in a timely manner.