(www.MaritimeCyprus.com) A key element of the MARPOL regulations is the requirement to record discharges of shipboard substances and materials which could cause pollution to the environment. Traditionally, these record books have been maintained in paper form.
With the maritime industry getting more digital, as of 01 October 2020, MARPOL has enabled the use of electronic record books in lieu of hard copy record books. Electronic recording may benefit the retention of records by companies/ships and will reduce the administrative burden associated with paperwork.
What Record Books?
- Oil Record Book, part I (MARPOL Annex I)
- Oil Record Book, part II (MARPOL Annex I)
- Cargo Record Book (MARPOL Annex II)
- Garbage Record Book, part I and II (MARPOL Annex V)
- Ozone-depleting Substances Record Book (MARPOL Annex VI)
- Recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI)
- Record of Fuel Oil Changeover (MARPOL Annex VI)
- Record Book of Engine Parameters (NOx Technical Code).
Approval of electronic record books
Before replacing a hardcopy record book, the electronic record book (ERB) will be subject to approval by the ship's Flag State. A set of guidelines for the use of ERBs under MARPOL has been developed by the IMO providing standardized information on approving ERBs. This is to ensure that the obligations of MARPOL are met and that there is a consistent approach to approving such systems.
There are available, relevant type approval programmes based on the IMO guidelines, from several Classification Societies. Owners/Managers should seek from the vendors such certification.
Installation onboard
When installed onboard, a “Declaration of MARPOL electronic record book” shall be issued to the ship by the Flag Administration or on behalf of the Flag by a Recognized Organization. This declaration will serve as proof of meeting the requirements, and it shall be kept onboard for the purpose of regulatory surveys or inspections.
Port State
Despite ERB being introduced in MARPOL, there may still be Port States which are reluctant towards ERBs. Hence, before going fully digital the option of replacing the hardcopy record book should be carefully considered based on the vessels trading area and ports of call. Before opting for and using a MARPOL ERB as the vessel’s official logbook the following should be confirmed:
- Do all relevant Port States accept MARPOL ERBs?
- Is the specific MARPOL ERB approved by the Flag Administration of the ship?
- Has a “Declaration of MARPOL electronic record book” been issued to the ship upon installation?
Recommendations
Electronic record books (ERBs) is supporting a broader goal of more effective ship operation, and it is recommended that shipowners and operators use this option. However, until ERBs have reached full acceptance in the industry, and - in particular - towards the Port States, it is also recommended doing an individual assessment to ensure, for example, that the relevant Port States accept MARPOL ERBs. Ofcourse, as already mentioned above, such ERB should be accompanied by a Type Approval certificate.
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 ERB should also have the capability to produce a hard copy of verified records for the master to certify as a true copy, upon request from relevant authorities, and to allow automatic backup of data in its system to offline storage.
Read more on Electronic Records Books, HERE
References:
Resolution MEPC.314(74) – Amendments to MARPOL Annexes I, II and V (Electronic Record Books)
Resolution MEPC.316(74)– Amendments to MARPOL Annex VI (Electronic Record Books and EEDI regulations for ice-strengthened ships)
Resolution MEPC.317(74) – Amendments to the NOx Technical Code 2008 (Electronic Record Books and Certification requirements for SCR systems)
Resolution MEPC.312(74) – Guidelines for the use of Electronic Record Books under MARPOL
