With the maritime industry getting more digital, from 1 October 2020, MARPOL will enable 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.
Relevant for ship owners and managers as well as flag states.
The MARPOL and NOx Technical Code amendments enter into force on 1 October 2020. The regulations enable the electronic recording of the following 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 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.
To assist ERB manufacturers and Flag Administrations, DNV GL is developing a type approval programme based on the IMO guidelines, including additional optional specifications for improved non-repudiation. The type approval can be applied for flags where DNV GL is delegated to approve ERBs or as documentation in the approval process towards other Flag Administrations.
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. When delegated, DNV GL may do the onboard installation survey – possibly remotely – and issue the declaration.
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 DNV GL recommends that shipowners and operators use this option. However, until ERBs have reached full acceptance in the industry, and - in particular - towards the Port States, we recommend doing an individual assessment to ensure, for example, that the relevant Port States accept MARPOL ERBs.
References
- MEPC.312(74) Guidelines for the use of electronic record books under MARPOL
- MEPC.314(74) Amendments to MARPOL Annexes I, II and V
- MEPC.316(74) Amendments to MARPOL Annex VI
- MEPC.317(74) Amendments to the NOx Technical Code 2008
Contact
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