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Electronic Record Books under MARPOL

One of the key elements of the International Convention for the Prevention of Pollution from Ships (MARPOL) is the accurate record keeping of movements and/or discharges of shipboard substances and materials that are considered hazardous to the environment.

We would like to advise Members that from 1 October 2020, amendments to MARPOL Annex I, II, V, VI and the NOx Technical Code1 will permit the use of electronic record books. These amendments follow resolutions2 adopted by the Marine Environment Protection Committee (MEPC) 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 be carried on board the ship.

In addition, Members should be reminded of the importance of proper record keeping and to ensure that all logs that are on board are maintained accurately and in a timely manner. Record books are an important document which not only exhibit regulatory compliance but also act as vital evidence in the unfortunate event of an incident. In the Club’s own experience consequences of erroneous or missing entries may include detention of a ship by Port State Control or monetary fines.

The Club would like to draw particular attention to the following guidance with regard to ensuring these official documents are completed accurately:

• IMO Guidance For The Recording Of Operations In The Oil Record Book Part I – Machinery Space Operations (All Ships)
• INTERTANKO – A Guide for Correct Entries in the Oil Record Book (Part I – Machinery Space Operations)
• INTERTANKO – A Guide for Correct Entries in the Oil Record Book (Part II – Cargo/ballast operations)

For further information Members are also advised to refer to the Guidelines for the use of electronic record books under MARPOL, adopted by resolution MEPC.312(74).
Source: The Shipowners’ Club

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