Environment and regulation

Three ways an electronic record book differs from paper and the Administration's declaration (MEPC.314(74) and MEPC.312(74))

MARPOL record books were paper for a long time. Resolution MEPC.314(74), adopted on 17 May 2019 and in force from 1 October 2020, put a definition of electronic record book into Annexes I, II and V. The Oil Record Book, the Cargo Record Book and the Garbage Record Book may now be kept electronically. MEPC.312(74), adopted the same day, is the guidance an Administration looks at when it approves one.

Moving a paper record book into a PDF or a spreadsheet does not make it an electronic record book. What the text requires is approval by the Administration, and the Guidelines are the criteria for that approval. This article reads the three points where an electronic record book departs from paper through the text of the Guidelines. The condition for saving an entry, what replaces the signature, and backup and copies. It ends with what has to be shown at an inspection.

An electronic record book is a record book only once the Administration has approved it

39 Electronic Record Book means a device or system, approved by the Administration, used to electronically record the required entries for discharges, transfers and other operations as required under this Annex in lieu of a hard copy record book.

This is the definition MEPC.314(74) put into Annex I regulation 1. The same sentence went into Annex II regulation 1 (paragraph 22) and Annex V regulation 1 (paragraph 19). The key words are approved by the Administration and in lieu of a hard copy record book. Only with the approval does it stand in for paper.

The second sentence of Annex V regulation 10.3 was replaced with the following.

The Garbage Record Book, whether as a part of the ship’s official logbook, or as an electronic record book which shall be approved by the Administration taking into account the Guidelines developed by the Organization, or otherwise, shall be in the form specified in appendix II to this Annex:

Sentences of the same shape went into the Oil Record Book Parts I and II (Annex I regulations 17.1 and 36.1) and the Cargo Record Book (Annex II regulation 15.1). For the unit the master signs, or group of electronic entries was added after each completed page. There are no pages in an electronic book, so a group of entries is the unit of signature.

The Guidelines cover seven record books

2.1 These Guidelines are only applicable to the use of electronic record books on board to meet the requirements of the following record books and recording requirements under the MARPOL Annexes and the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (NOX Technical Code): .1 Oil Record Book, parts I and II (MARPOL Annex I, regulations 17.1 and 36.1); .2 Cargo Record Book (MARPOL Annex II, regulation 15.1); .3 Garbage Record Book, parts I and II (MARPOL Annex V, regulation 10.3); .4 Ozone-depleting Substances Record Book (MARPOL Annex VI, regulation 12.6); .5 recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI, regulation 13.5.3); .6 Record of Fuel Oil Changeover (MARPOL Annex VI, regulation 14.6); and .7 Record Book of Engine Parameters (NOX Technical Code, paragraph 6.2.2.7).

The four under Annex VI and the NOx Technical Code were amended by MEPC.316(74) and MEPC.317(74). This article gives only the numbers of those two resolutions and does not go into their text. Paragraph 2.3 of the Guidelines says they do not cover documents such as certificates that do not log continuous operations. Paragraph 2.4 draws a line around the exchange of data from ship to company, which is not a record book requirement. An electronic record book is a recording device on board, not a reporting system.

First, an entry with a missing field cannot be saved, and a correction leaves its trace

4.1.2 As MARPOL specifies the recording of a range of information for specific circumstances, an approved system should only allow a complete entry to be saved for verification by the master. For example, for a MARPOL Annex V discharge at sea, the entry should not be able to be saved without the entry of the latitude and longitude of the discharge. It is suggested that where possible, technology which can automatically input required data be installed to ensure accuracy. In the case of equipment failure, manual input should be allowed and the change of the source of data recorded. The automatic data value inputs should be protected by measures aimed at preventing attempts at manipulation or falsification. The system should automatically record any attempts to manipulate or falsify any data.

On paper, a position can be left blank and the entry signed anyway. An electronic record book should allow only a complete entry to be saved. Equipment that takes the position automatically is suggested, and when it fails, manual input is opened and the change of data source is recorded. An attempt at manipulation is itself recorded.

4.3.4 Records and entries should be protected by measures aimed at preventing and detecting attempts at unauthorized deletion, destruction or amendment. After an entry is saved by the user, the system should secure the information against unauthorized or untraceable changes. Any change(s) to the entry by the same user or a different user should be automatically recorded and made visible both in the system and in any output presentation or printed versions of the electronic record book. The entry should appear in the list of entries in a format that makes it clear that the entry has been amended. To create transparency of changes to saved or verified entries, it is essential that the system is designed to retain both the original entry and the amendment(s).

A saved entry cannot be deleted or overwritten. When it is amended, both the original and the amendment remain, and the fact of amendment has to be visible on screen and in print. Paragraph 4.3.5 recommends recording the reason and the identifier of the person amending, for the master to verify. The struck-through correction on paper becomes retained history in electronic form.

4.3.1 To ensure the security of an electronic record book, it is critical that the system implements Role Based Access Control. At a minimum, all access to the application should use a unique personal login identifier and password for each user. This level of security ensures that the user making entries into the application is accountable for any false entries or omissions. 4.3.2 MARPOL requires the signature of the relevant officer entering a record. As such, the electronic record book should implement Audit Logging. Audit Logging should record a user code, identifying symbol, such as a graphic character, or an equivalent identifier against each entry to uniquely identify the user and whether the user provided accessed or amended an entry.

The signature of the officer in charge is replaced by a personal login and an audit log. A shared account does not meet this condition. Who made the entry and who accessed or amended it has to remain against each entry.

4.3.6 MARPOL also requires that information in the record book be verified (e.g. regulation 17 of MARPOL Annex I requires that each page of the Oil Record Book be signed by the master of the ship). For verification of a single or series of saved entries by the master, the electronic record book should have an additional authentication factor to allow verification. This additional authentication factor should be in the form of additional credentials supplied by the master at the time of verification.

The master’s page signature becomes a verification step. The master supplies additional credentials, separate from the login, at the time of verification. Paragraph 4.3.8 asks for a status field on each entry with terms such as pending and verified. Paragraph 4.3.9 says an entry amended after verification returns automatically to pending and the master is notified for re-verification. Paragraph 4.3.7 has the system log the time of entry, amendment and verification separately, so that several days entered at one sitting leave a visible trace. Annex V regulation 10 requires entries to be promptly recorded. Paragraph 4.3.10 recommends verification before arrival in port and a comment giving the reason for any unverified entry. Paragraph 4.3.11 lets a reception facility receipt or a survey endorsement be attached to or referenced from the entry, with the original retained.

Third, backup is automatic and the offline copy carries the master’s digital signature

4.4.2 The electronic record book should have the capability to allow automatic backup of data in the system to offline storage. Backups should ensure the offline record is updated automatically every time changes are made to entries to ensure the backing up process is not forgotten by the user.

A backup that depends on someone remembering to run it is ruled out by the Guidelines. The offline store has to update automatically every time an entry changes. Paragraph 4.4.1 puts the electronic record book into the company’s IT business continuity plan and asks for alternate power supplies so the system can still be reached when power is lost. If the system cannot be opened during an inspection, paragraph 6.1.2 has the inspector ask for an alternative verified copy or a hard copy record book.

4.4.4 This offline record may be provided in any format deemed appropriate by the Administration and should be digitally signed by the master. The properties of the digital signature need to appear on the offline record, including the title; full name of the signer; and date and time of signing. It is recommended that the document be presented in PDF; however, an alternative format may be used. Alternative formats should allow the exchange and view of electronic documents independent of the environment in which they were created and the environment in which they are viewed or printed, in a simple way and with fidelity.

The offline copy has to be encrypted and read-only (4.4.3) and digitally signed by the master. The title, full name of the signer and the date and time of signing have to appear on the copy. PDF is recommended, but the Administration may accept another format. Paragraph 4.1.4 requires all records to be retained for the minimum period each Annex sets. On request, a hard copy has to be producible for the master to certify as a true copy.

The declaration has to be on board and the inspector may ask for a printout

5.1 Any electronic system deemed to meet the above criteria should be provided with written confirmation by the Administration and carried on board the ship for the purpose of regulatory surveys or inspections. An example of a declaration can be seen in the appendix.

The evidence of approval is written confirmation by the Administration, that is, the declaration. The example form in the appendix carries the ship’s name, IMO number, flag State, the Annexes applied, the manufacturer, supplier and installer, the software name and version, and the date of installation. Paragraph 5.2 leaves it to the Administration whether to delegate the assessment and the issue of the declaration to a recognized organization.

6.1.2 The use of and reliance upon electronic record books in no way relieves shipowners of their existing duty to accurately maintain and produce records during an inspection, as required by MARPOL. It is recommended that if a ship cannot produce the electronic record book or a declaration provided by the Administration during the PSC inspection, the PSC officer should request to view an alternative verified copy of the records or a hard copy record book for verification.

Without the declaration, or with a system that will not open, the PSC officer asks for an alternative verified copy or a hard copy record book. Paragraph 6.2 says the records should be viewable on the ship’s own equipment so that officers need not bring their own. When an investigation opens, paragraph 6.3 has the relevant entries or the whole book printed, with the master signing each page to certify it as a true copy. The printout has to show the title and full name of the person who entered the record, any changes made, the date and time of printing, the name and version of the software, and page numbering with the total number of pages.

Worth confirming

MEPC.312(74) is guidance, so its text is written with should. The binding force comes from the words approved by the Administration in the Annex text as amended by MEPC.314(74). So the approval procedure and the form of the declaration may differ from one flag State to another even for the same software. Paragraph 4.2 says the software has to be updated before a MARPOL amendment enters into force, without losing existing records or making them unreadable. The amendments to the Annex VI record books are not covered by this article.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

Scattered records hide the pattern

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