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MARPOL amendments to permit electronic record books

The International Maritime Organisation (IMO) in 2019 adopted the Guidelines for the use of Electronic Record Books under MARPOL (Resolution MEPC.312(74)) (IMO Guidelines), which state that: ‘the use of an electronic record book to record operational logs is an alternative method to a hard copy record book. The electronic record book may allow ships to utilize their technology to reduce administrative burdens and contribute to on board environmental initiatives, e.g. reduction of paper use.’

At the same time as adopting the Guidelines, the IMO also adopted consequential amendments to MARPOL Annexes I, II and V (Resolution MEPC.314(74)) and MARPOL Annex VI (Resolutions MEPC.316(74) and MEPC.317(74)) which enter into force on 1 October 2020.

ISO’s Standard for ERBs

The International Standards Organization (ISO) released its document on Electronic record books for ships — Technical specifications and operational requirements’, ISO 21745:2019, at the end of 2019. The document specifies the minimum technical and operational requirements for ERBs to be used on ships, establishing requirements for the design and testing of ERBs by manufacturers. However, it also provides detailed technical guidance on key ERB performance elements including system database backup and recovery, data storage, tampering avoidance and the system’s integration with other bridge electronic equipment. As such, it is worthwhile reviewing this document in conjunction with the IMO’s Guidelines and as part of the information gathering and due diligence prior to contacting the suppliers.

These amendments follow resolutions adopted at Marine Environment Protection Committee (MEPC) 74 in May 2019, and are applicable to:

  • Oil Record Book, parts I and II
  • Cargo Record Book
  • Garbage Record Book, parts I and II
  • Ozone-depleting Substances Record Book
  • Recording of the tier and on/off status of marine diesel engines
  • Record of Fuel Oil Changeover; and
  • Record Book of Engine Parameters.

An electronic record book used as an alternative to an official hard copy record book is required to be assessed by the Flag Administration following which a written confirmation (Declaration of Marpol Electronic Record Book) will be issued. A copy of this declaration should exist onboard the ship.

Benefits of using ERBs

Some of the main benefits of introducing ERB software include: 

  • assisting with the record keeping aspects of MARPOL and consequently streamlining the administrative burden associated with Flag Administration requirements;
  • assisting with port State control inspections where ERBs are accepted by port State authorities;
  • eliminating clerical errors and mistakes;
  • assisting ship staff with monitoring and ensuring compliance by positive validation and prompts when necessary.

The latter two points should assist in preventing regulatory violations. Depending on the software package and how this is implemented within the company, including the interface between ship(s) and shore, additional benefits may include:

  • a real time visibility of activities on board, which can lead to;
  • an improved transparency and awareness of the daily operations conducted on board, which may in turn allow;
  • the establishment of more clear and accurate statistics and trends; 
  • possibility of conducting remote audits. 


Consultation with the Administration

The IMO has amended each Annex of MARPOL to allow Administrations to authorise and approve the use of ERBs. Many administrations have welcomed the introduction of ERBs and have reviewed and recommended certain types of products and platforms, which may as a consequence limit the options available to your company. Consideration should be given to the requirements that may be put in place by the Administration and to explore whether they have issued additional guidance and requirements for approving ERBs for use on board.
Selecting a supplier that has already worked with the major Administrations may assist with system approvals and reduce the administrative burden for the company and supplier compared to introducing a new product or platform that requires review and approval by the Administration. There is also a risk that a system that has been introduced without the prior or early approval of the Administration may fail to attain approval.