Guidelines for use of MARPOL Electronic Record Books (“ERBs”)
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.
On 17 May 2019, IMO's MEPC 74 adopted the resolutions below to allow for ERBs to be used. Guidelines to support the use of ERBs were also adopted by the Committee. These amendments, which will reduce the heavy burden associated with paperwork and which are thus to be welcomed, will enter into force on 1 October 2020;
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
The Guidelines are only applicable to the use of ERBs on board to meet the requirements of the following record books and recording requirements under MARPOL Annexes I, II, V & VI and the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (NOX Technical Code):
- Oil Record Book, parts I and II (MARPOL Annex I, regulations 17.1 and 36.1);
- Cargo Record Book (MARPOL Annex II, regulation 15.1);
- Garbage Record Book, parts I and II (MARPOL Annex V, regulation 10.3);
- Ozone-depleting Substances Record Book (MARPOL Annex VI, regulation 12.6);
- Recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI, regulation 13.5.3);
- Record of Fuel Oil Changeover (MARPOL Annex VI, regulation 14.6); and
- Record Book of Engine Parameters (NOX Technical Code, paragraph 220.127.116.11).
An ERB is defined in the Guidance as a device or a system used to electronically record entries. When an ERB is to be used as an alternative to an official hard copy record book onboard a ship, the State’s Administration is required to assess the device or system and to issue a “Declaration of Marpol Electronic Record Book”. A copy of this declaration must be kept onboard the ship. The procedures related to the use of ERBs must be documented in the ship’s Safety Management System (SMS).
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.
If Members have any questions on the above, please reach out to your usual contact at the Club.
Source Legal Services Manager
You may also be interested in:
Legal Update: The IMO Marine Environment Protection Committee (MEPC) 74th Session - Summary
The IMO Marine Environment Protection Committee (MEPC) met for its 74th session at the IMO Headquarters in London from 13-17 May. Below is a summary of the outcome from this meeting on the following topics
ECM Client Alert 01-2020 - USCG: Implementation of MARPOL Annex VI - Revised Guidance CVC-WI-022
The USCG’s Office of Commercial Vessel Compliance (CG-CVC) has issued an updated guidance outlining how it will enforce Marpol Annex VI requirements, including the IMO 2020 Sulphur cap, within the two US. Emission Control Areas (ECA). Initial guidance on enforcement is also provided to USCG units not within either ECA. Please see ECM Maritime Services.LLC’s Client Alert 1-2020 for full details. Members are asked to note that the guidance previously provided in CG-CVC Policy Letter 12-04 Change 1 has been cancelled with immediate effect.
MARPOL Annex V Garbage Record Book - Liberia Publishes two new Garbage Record Books for Ships
The amendments include revised guidelines and format for the Garbage Record Book (GRB) required to be maintained on board ships. The new revised GRB is divided into Parts I & II.