News: US adopts MARPOL amendments regarding electronic recordkeeping
13 October 2020
Members have been previously advised that from 1 October 2020 the use of Electronic Record Books (ERBs) in lieu of paper record books comes into force following amendments to MARPOL Annexes I, II, V, VI and the NOx Technical Code. Please see here the respective guidelines for the use of ERBs.
The United States had not been previously in favor of adopting the amendments and thus accepting the Marpol ERBs used by ships. However, through a recent short statement, USCG advised that the Coast Guard Port State Control Officers (PSCO) and Marine Inspectors will begin examining ERBs in a similar manner as written record books. PSCO would be also seeking for written confirmation from the Flag Administration that the electronic system meets the criteria provided in IMO Resolution MEPC.312(74).
An article from Blank Rome provides an overview on this topic. Further, should members require practical guidance for selecting ERBs products and suppliers they can reach out to Intertanko that has released a guidance document.
Members are reminded of the importance of proper and accurate record keeping to achieve regulatory compliance and avoid significant fines from the government authorities.
If members have any questions or feedback on the above, please reach out to the undersigned or your usual contact at the club.