Electronic Record Books – An available option to hard copy records

As the maritime industry becomes increasingly digital, the adoption of electronic records over traditional hard copy record books is steadily growing. This shift to electronic recording can enhance record retention for companies and ships, while also alleviating the administrative burden of paperwork.

As of October 1, 2020, new amendments to MARPOL and the NOx Technical Code (NTC) entered into force, allowing the use of MARPOL electronic record books (MERB). Vessels now have the option to replace hard copy oil record books with electronic versions approved by the flag administration. The amendments permit electronic versions of the following:

  • 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, parts I and II (MARPOL Annex V)
  • Ozone-depleting Substances (ODS) 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)
  • EGCS record book (EGCS guidelines)

*The ODS record book was already permitted on an electronic record system before 2020. IMO allowed until the first IAPP renewal survey carried out on or after October 1, 2020, but not later than October 1, 2025, to have it approved by the flag administration.

Ballast water management convention amendments

Starting October 1, 2025, new amendments to the Ballast Water Management (BWM) convention will enter into force. From that date, the approval of electronic BWM record books (BWERB) by the flag Administration is required if used on board a ship to replace hard copy records.

Type approval of ERB

A MERB or BWERB must be approved by the flag administration if used to replace the hard copy record book. Typically, MERB or BWERB will come with a Type Approval Certificate (TAC) issued by DNV or another recognized organization (RO). Approval for MERB must comply with IMO Resolution MEPC.312(74) – guidelines for the use of electronic record books under MARPOL, and for BWERB, it must comply with Resolution MEPC.372(80) – guidelines for the use of electronic record books under the BWM Convention. Additionally, potential flag-specific requirements must be met.

Declaration of ERB

When installed onboard, a “Declaration of MARPOL ERB” must be issued to the ship by the flag administration or an RO on behalf of the flag. This declaration serves as proof of meeting the requirements as installed and must be kept onboard for regulatory surveys or inspections. Similarly, a ship-specific “Declaration of BWERB” must be issued based on a survey confirming that the
installation of the BWERB meets IMO requirements. When delegated, DNV may conduct the installation survey and issue the declaration. If DNV is not authorized, the vessel owner must consult the flag directly.

Survey and Issuance of Declaration by DNV

The survey for issuance of the declaration may typically be conducted as a remote survey. Required documents include:

  • Electronic Record Book (ERB) TAC and/or flag acceptance letter.
  • Manufacturer's on-board verification procedure or installation checklist completed by the ERB installer.
  • Declaration by the ERB manufacturer or supplier confirming:
    • Verification of correct functioning following installation on board.
    • Compliance with IMO Resolutions MEPC.312(74) paragraph 4.4.5 for MARPOL / MEPC.372(80) paragraph 4.4.5 for ballast water management.
    • Compliance with hardware requirements and all other conditions stipulated in the ERB TAC and/or flag acceptance letter, including reference to TAC number and/or flag acceptance letter.
  • Statement from master confirming:
    • ERB type installed, and which record book(s) are covered.
    • ERB manufacturer, supplier, and installer name.
    • Installation according to manufacturer's specification.
    • Appropriate user profiles have been established.
    • Company verification/audit requirements, such as integration with the ship's safety management system, are met.
  • Dated screen dump showing ERB software name and version installed on board. The vessel name must be visible.

When issued, the declaration will be visible in Veracity under "Main Certificates" without an expiry date or follow-up. In the case of a software version update, a new declaration is required.

Discontinuance

If an ERB is taken out of service, e.g., if changing to another system or to a hard copy record book, the relevant pages should be printed and certified as a true copy by the vessel’s master and retained on board for at least the period specified in the convention. DNV must be informed, and the declaration must be removed from Veracity.

Port State

Despite ERB being introduced in MARPOL and the BWM Convention, some port states may still be reluctant towards ERBs. Before going fully digital, the option of replacing the hardcopy record book should be carefully considered based on the vessel's trading area and ports of call. Before opting for and using an ERB as the vessel’s official logbook, the following should be confirmed:

  • Do all relevant port states accept ERBs?
  • Is the specific ERB approved by the flag administration of the ship?
  • Has a “Declaration of ERB” been issued to the ship upon installation?

Other electronic logbooks

Other logbooks, such as those for deck, radio, engine room, etc., in electronic format are not yet clearly addressed by the IMO. For these logbooks, the flag can normally be consulted directly without the involvement of DNV, unless in rare cases where the flag has delegated responsibilities for these logbooks.

Norwegian flag

MERB: The Norwegian Maritime Authority (NMA) has authorized DNV for both type approval of MERB and issuance of the ship-specific declaration.

BWERB: Regarding BWERB, NMA does not require type approval in accordance with "Resolution 372(80)" until October 1, 2025. Consequently, NMA accepts the use of BWERB without a ship-specific declaration until that date. From October 1, 2025, or earlier if instructed by the NMA, type approval will be required, and a “Declaration of BWERB” must be issued when the BWERB replaces the hardcopy record book on board.

Declaration of MARPOL Electronic Record Book (MERB)

Declaration of BWM Convention Electronic Record Book (BWERB)

 

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13.03.2025 14:32:00