Commandant
United States Coast Guard

2703 Martin Luther King Jr. Ave., S.E.
Washington, DC 20593-7509
Staff Symbol: CG-ENG
Phone: 1 (202) 372-1375
Email: CGENG@uscg.mil

COMDTPUB P16700.4
NVIC 01-23
August 4, 2023
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23

Subj:

GUIDANCE FOR THE VOLUNTARY USE OF MARPOL ELECTRONIC RECORDBOOKS ON U.S. FLAG VESSELS

Ref:(a) International Maritime Organization (IMO) Marine Environmental Protection Committee
Resolution MEPC.312(74)(b) International Maritime Organization (IMO) Marine Environmental Protection Committee
Resolution MEPC.314(74)(c) International Maritime Organization (IMO) Marine Environmental Protection Committee
Resolution MEPC.316(74)(d) International Maritime Organization (IMO) Marine Environmental Protection Committee
Resolution MEPC.317(74)(e) 46 CFR Part 8(f) International Convention for the Prevention of Pollution from Ships (MARPOL), 2022
(g) The Code for Recognized organizations (RO Code)PURPOSE. This Navigation and Vessel Inspection Circular (NVIC) provides guidance on the U.S.
Coast Guard’s process and criteria for assessing, accepting, and verifying onboard electronic record
books under the amendments to MARPOL Annexes I, II, V and VI and the Technical Code on Controlof Emission of Nitrogen Oxides from Marine Diesel Engines (NOx Technical Code 2008). The UnitedStates adopted the MARPOL Convention amendments in references (b)-(d), which entered into force on
October 01, 2020. This circular provides guidance for U.S.-flagged vessels that choose to comply withMARPOL record keeping requirements through the use of electronic record books. This circular also
provides guidance for foreign-flagged vessels using electronic record books while operating in U.S.
waters.
1. ACTION. Headquarters offices under the Assistant Commandant for Prevention Policy and Officers
in Charge, Marine Inspection are encouraged to bring this circular to the attention of the marine
industry and other marine interests within their areas of responsibility. Internet release is authorized.
2. DIRECTIVES AFFECTED. None.

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23
3. BACKGROUND.
a. As ship owners and operators increasingly focus on ways to operate in an environmentally
responsible manner and aim to ease the burden associated with paperwork through electronicmeans, keeping operational logs in an electronic format has become a popular consideration.
The use of electronic record books has benefits for the retention of records by companies, crew,
and officers.
b. The use of an electronic record book is an alternative method to a hard-copy record book. The
electronic record book allows ships to utilize shipboard technology to reduce administrative
burdens and contribute to onboard environmental initiatives (e.g., reduction of paper use).
Existing U.S. regulations do not specifically address the design and installation of electronic
record books on commercial vessels.
4. DISCLAIMER. This guidance is not a substitute for applicable legal requirements, nor is it itself arule. It is not intended to nor does it impose legally-binding requirements on any party. It represents
the Coast Guard’s current posture on this topic and may assist industry, mariners, the general public,
and the Coast Guard, as well as other federal and state regulators, in applying statutory andregulatory requirements. You can use an alternative approach for complying with theserequirements if the approach satisfies the requirements of the applicable statutes and regulations.
5. DISCUSSION.
a. In May of 2019, the IMO adopted amendments to MARPOL Annex I, II, V, VI, and theTechnical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (NOxTechnical Code 2008), to enable the use of electronic record books, references (b)-(d). These
amendments entered into force on October 1, 2020.
b. Simultaneously, the IMO recognized the need to develop guidance for the use of electronic
record books and adopted such guidelines with IMO Resolution MEPC.312(74), reference (a),enclosure (1).
6. PROCEDURE. This circular provides guidance for U.S.-flagged vessels choosing to use electronic
record books to satisfy the recordkeeping and logbook requirements established in MARPOL. This
circular sets forth the two-step process for assessing electronic record book systems for compliancewith guidance issued by the IMO and the onboard verification and issuance of a “Declaration of
MARPOL Electronic Record Book” certificate or letter. Coast Guard port state control officers willverify that foreign-flagged vessels using electronic record books while operating in U.S. waters do
so in accordance with administration-approved documentation, as outlined below.
a. Applicable record books: This circular applies to any U.S.-flagged vessel seeking to use
electronic record books to meet the recordkeeping requirements in the following MARPOL
regulations:(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);
2

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23(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).
b. Manufacturers seeking assessment of electronic record books: Manufacturers of electronic
record books seeking to obtain acknowledgment of assessment for general compliance of theirproduct with reference (a) should email their request and supporting documentation noted below
to the Coast Guard Office of Design and Engineering Standards (CG-ENG) at:
CGENG@uscg.mil.
(1) Manufacturers should obtain and provide documentation attesting to the product’s ability tocomply with the various International Organization for Standardization (ISO) andInternational Electrotechnical Commission (IEC) standards referenced within MEPC.312(74)from an Authorized Classification Society (ACS). The ACS making this attestation mustpossess authorization to issue the MARPOL certificate that corresponds to the electronic
record book. 1 The documentation should attest to the product’s ability to comply with thefollowing:i.

Audit Logging requirements as outlined by ISO/IEC 27001:2006.

ii.

Credential requirements as outlined by ISO 7498-2.

iii.

Cryptography requirements as outlined by ISO 7498-2.

iv.

Data Requirements as outlined by ISO/IEC 2382-1.

v.

Digital Signature requirements as outlined by ISO 7498-2.

vi.

Functional Unit requirements as outlined by ISO/IEC 2382-1:1993.

vii.

Graphic Character requirements as outlined by ISO 1282-4.

viii.

Portable Document Format requirements as outlined by ISO 32000.

ix.

Private Key requirements as outlined by ISO/IEC 9594-8.

x.

Public Key requirements as outlined by ISO/IEC 9594-8.

1

See 46 CFR Part 8 and the individual ACS agreements at: https://www.dco.uscg.mil/Our-Organization/AssistantCommandant-for-Prevention-Policy-CG-5P/Inspections-Compliance-CG-5PC-/Commercial-Vessel-Compliance/Flag-StateControl-Division/ClassSocAuth/

3

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23

xi.

Role Based Access Control requirements as outlined by ISO/IEC 27033-2:2012.

xii.

Storage requirements as outlined by ISO/IEC 2382-1:1993.

(2) Following a review of the documentation requested in paragraph 1 of this section, CG-ENG
may require in-person or virtual demonstration of the electronic record book by the
manufacturer requesting the acknowledgment of assessment for general compliance.
(3) Electronic record books that receive an acknowledgment of assessment for generalcompliance with MEPC.312(74) will be listed on the Coast Guard’s website(https://www.dco.uscg.mil/CG-ENG/). It is important to note that this acknowledgment by
the Coast Guard does not constitute allowance for use on a particular U.S.-flagged vessel.
This acceptance authorizes those electronic record books to be considered for use on a U.S.flagged vessel, as outlined below.
c. U.S.-flagged vessels seeking use of assessed electronic record books: In order to use a Coast
Guard assessed electronic record book to meet MARPOL requirements, ship owners andoperators must obtain a Declaration of MARPOL Electronic Record Book. Per 46 CFR § 8.130,
the Coast Guard has delegated authority to multiple ACS to issue convention certificates onbehalf of the United States. For the purpose of electronic record books, an ACS with MARPOL
delegations may issue a “Declaration of MARPOL Electronic Record Book” if the ACS
possesses the specific authorization for the delegation from which that electronic record bookstems. 2 For example, an ACS that may issue an International Oil Pollution Prevention Certificate
on behalf of the United States may also issue the “Declaration of MARPOL Electronic Record
Book” for Oil Record Book Parts I and II.
(1) Ship owners and operators seeking to use an accepted product listed on the Coast Guard’s
website (https://www.dco.uscg.mil/CG-ENG/) should apply to the ACS that issued theapplicable IMO certification. Per the Recognized Organization (RO) Code, Part 2.3, an ACS
and its staff responsible for carrying out the statutory certification and services related to the“Declaration of MARPOL Electronic Record Book” shall not be the designer, manufacturer,
supplier, installer, purchaser, owner, user, or maintainer of the item subject to the statutory
certification and services, nor the authorized representative of any of these parties.
(2) An ACS may require the following information prior to issuing an approved “Declaration of
MARPOL Electronic Record Book”:

2

A complete list of ACSs with individual authorizations is located on the Coast Guard’s website:
https://www.dco.uscg.mil/Our-Organization/Assistant-Commandant-for-Prevention-Policy-CG-5P/Inspections-ComplianceCG-5PC-/Commercial-Vessel-Compliance /Flag-State-Control-Division/ClassSocAuth/.

4

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23
i. the name of the ship;
ii. the IMO number;iii. the official number;
iv. the gross tonnage; andv. for each electronic record book sought to be implemented:(a) the manufacturer;(b) the supplier (if different);(c) the installer (if different);(d) the software name/version; and(e) the date of installation for each electronic record book.
(3) Upon successful application and onboard verification by the ACS in accordance withreference (a) section 4, the vessel will be issued a “Declaration of MARPOL Electronic
Record Book” from an ACS on behalf of the United States Government. This declaration
will be required to be kept onboard the vessel for inspection.
(4) If a vessel is not serviced by an ACS, the owner or operator may apply to the local Officer in
Charge, Marine Inspection (OCMI) for a “Declaration of MARPOL Electronic Record
Book” to use an accepted product that is listed on the Coast Guard’s website(https://www.dco.uscg.mil/CG-ENG/).
(a) Upon successful application and onboard verification by a Coast Guard marine
inspector, in accordance with reference (a) section 4, the OCMI will issue a “Declarationof MARPOL Electronic Record Book” letter.
(b) This declaration will be required to be kept onboard the vessel for inspection.
(5) For inspection and surveying purposes, approved systems shall operate in accordance withreference (a).
(6) Ship owners and ship operators shall ensure the continued compliance with all MARPOL
requirements.
d. Safety Management System (SMS): Vessels with a SMS and an electronic record book shouldhave procedures for the use and maintenance of the electronic record books integrated into their
SMS. The OCMI may survey or inspect the vessel to ensure the procedures for electronic record
books are properly integrated within the vessel’s SMS prior to issuing a “Declaration of
MARPOL Electronic Record Book” certificate or letter.

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NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23
e. Foreign-flagged vessels: While operating in U.S. waters, owners and operators of foreignflagged vessels that elect to comply with MARPOL record keeping requirements through the useof electronic record books will be expected to demonstrate compliance with reference (a)through written documentation from their flag administration or from their Recognized
Organization acting on behalf of the administration. Such written documentation should be
carried on board the ship for the purpose of regulatory surveys or inspections.
7. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS.
a. The development of this NVIC and the general policies contained within it have been thoroughly
reviewed by the originating office in conjunction with the Office of Environmental Management,
Commandant (CG-47). This NVIC is categorically excluded under current Department ofHomeland Security (DHS) categorical exclusion (CATEX) A3 from further environmental
analysis in accordance with “Implementation of the National Environmental Policy Act(NEPA),” DHS Instruction Manual 023-01-001-01 (series).
b. This NVIC will not have any of the following: significant cumulative impacts on the humanenvironment; substantial controversy or substantial change to existing environmental conditions;or inconsistencies with any Federal, State, or local laws or administrative determinations relating
to the environment. All future specific actions resulting from the general policy in this NVIC
must be individually evaluated for compliance with the National Environmental Policy Act(NEPA), Department of Homeland Security (DHS) and Coast Guard NEPA policy, andcompliance with all other applicable environmental mandates.
8. RECORDS MANAGEMENT CONSIDERATIONS. This NVIC has been thoroughly reviewed
during the directives clearance process, and it has been determined there are no further records
scheduling requirements, in accordance with the Federal Records Act (44 U.S.C. § 3101 et seq.),
National Archives and Records Administration requirements, and the Information and Life Cycle
Management Manual, COMDTINST M5212.12 (series). This policy does not create significant or
substantial change to existing records management requirements.
9. CHANGES. This circular is available online at http://www.dco.uscg.mil/our-organization/nvic/.
The Coast Guard will issue and post time sensitive amendments as an urgent change message on its
website for the benefit of the industry. Interested parties may suggest improvements to this circular
by writing to the office responsible for implementing this guidance listed under Contact Information.
10. CONTACT INFORMATION. For more information on this section including equipment
certification or design review, or questions regarding implementation of this NVIC, please contact
CG-ENG staff electronically at CGENG@uscg.mil. Alternatively, you may contact CG-ENG staff
via physical mail at:

6

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01-23
COMMANDANT (CG-ENG)
US COAST GUARD HEADQUARTERS STOP 7430
2703 MARTIN LUTHER KING JR. AVE. S.E.
WASHINGTON, D.C. 20593-7430
11. FORMS/REPORTS. None.

W. R. Arguin
Rear Admiral, U. S. Coast Guard
Assistant Commandant for Prevention Policy
Enclosure:(1) MEPC.312(74) - “Guidelines for the use of electronic record books under MARPOL”

7

MEPC 74/18/Add.1
Annex 1, page 1
ANNEX 1RESOLUTION MEPC.312(74)(adopted on 17 May 2019)
GUIDELINES FOR THE USE OF ELECTRONIC RECORD BOOKS UNDER MARPOLTHE MARINE ENVIRONMENT PROTECTION COMMITTEE,RECALLING Article 38(a) of the Convention on the International Maritime Organization
concerning the functions of the Marine Environment Protection Committee conferred upon it
by international conventions for the prevention and control of marine pollution from ships,
NOTING resolutions MEPC.314(74), MEPC.316(74) and MEPC.317(74), by which it adopted
amendments to MARPOL Annexes I, II, V and VI and the Technical Code on Control ofEmission of Nitrogen Oxides from Marine Diesel Engines (NO X Technical Code 2008),
respectively, to enable the use of electronic record books,
RECOGNIZING the need to develop guidance for the use of electronic record books,
HAVING CONSIDERED, at its seventy-fourth session, the draft Guidelines for the use ofelectronic record books under MARPOL, prepared by the Sub-Committee on Pollution
Prevention and Response, at its fifth session,
1
ADOPTS the Guidelines for the use of electronic record books under MARPOL, thetext of which is set out in the annex to this resolution;
2
INVITES Governments to apply the Guidelines as soon as possible, or when theabove-mentioned amendments to MARPOL Annexes I, II, V and VI and the NO X Technical
Code 2008 enter into force;
3

AGREES to keep the Guidelines under review in light of experience gained.

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MEPC 74/18/Add.1
Annex 1, page 2
ANNEX
GUIDELINES FOR THE USE OF ELECTRONIC RECORD BOOKS UNDER MARPOL
1

INTRODUCTION

1.1
A key element of the International Convention for the Prevention of Pollution from Ships(MARPOL) regulations is the recording of discharges associated with the prevention of pollution
from ships. A number of MARPOL Annexes require the recording of particular discharges.
1.2
The format for the recording of discharges under MARPOL is provided in the
appendixes to the relevant MARPOL Annexes. Traditionally, the format of these record books
has been provided in hard copy by the Administration. However, as companies and shipowners
increasingly focus on ways to operate in an environmentally responsible manner and aim to
reduce the heavy burden associated with paperwork through electronic means, the concept ofoperational logs in an electronic format has become a popular consideration.
1.3
It is considered that this approach to recording and reporting should be encouraged
as it may have many benefits for the retention of records by companies, crew and officers.
1.4
It is expected that as companies and shipowners increasingly explore electronic
record keeping, flag State Administrations will be requested to approve electronic recording
systems (henceforth referred to as an electronic record book). This guidance aims to provide
standardized information on approving an electronic record book to ensure the obligations of
MARPOL are met and that there is a consistent approach to approving such systems.
2

APPLICATION

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
regulation 12.6);.5recording 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 ofparagraph 6.2.2.7).

Substances

EngineRecordBook

Parameters(MARPOL

(NOX

Annex

Technical

VI,

Code,

2.2
The use of an electronic record book to record operational logs is an alternative
method to a hard copy record book. The electronic record book may allow ships to utilize theirtechnology to reduce administrative burdens and contribute to on board environmental
initiatives, e.g. reduction of paper use.
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MEPC 74/18/Add.1
Annex 1, page 3
2.3
These Guidelines do not provide information on the management of electronic accessto, or electronic versions of, certificates and other documents that do not log continuous
operations of a ship.
2.4
These Guidelines do not address the exchange of information from a ship to acompany headquarters or other body, as this exchange is not a requirement of record books
under MARPOL.
2.5
If a shipowner decides to use an electronic record book to record operational logs,
instead of a hard copy record book, the following guidance should be taken into considerationby the Administration when approving the electronic record book for use.
3

DEFINITIONS

For the purposes of these Guidelines, the following definitions apply to the extent consistent
with MARPOL:.1

Administration: means the Government of the State under whose authority
the ship is operating. With respect to a ship entitled to fly a flag of any State,
the Administration is the Government of that State. With respect to fixed or
floating platforms engaged in exploration and exploitation of the seabed andsubsoil thereof adjacent to the coast over which the coastal State exercises
sovereign rights for the purposes of exploration and exploitation of theirnatural resources, the Administration is the Government of the coastal State
concerned.

.2

Audit Logging: means logs recording user activities, exceptions andinformation security events, where logs are kept for an agreed period to assistin future investigations and access control monitoring (ISO/IEC 27001:2006).
The time and date for the log should be Universal Co-ordinated Time (UTC)derived from ship's time.

.3

Backup: means to make a duplicate copy of a file, program, etc. as asafeguard against loss or corruption of the original. The specific propertiesof the backup such as its format, frequency, storage location, retention
period, are unique to each business organization and should be defined inaccordance with a Business Continuity Plan.

.4

Business Continuity Plan: means a collection of procedures andinformation that is developed, compiled and maintained in readiness for use
in the event of an emergency or disaster.

.5

Company: means the Owner of the ship or any other organization or personsuch as the Manager or the Bareboat Charterer, who has assumed the
responsibility for the operation of the ship from the shipowner and who on
assuming such responsibility has agreed to take over all the duties andresponsibility imposed.

.6

Credentials: means data that is transferred to establish the claimed identityof an entity. (ISO 7498-2). Examples of credentials include a unique
code/password, electronic key, digital certificate, hardware key, biometricdata (e.g. fingerprint).

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MEPC 74/18/Add.1
Annex 1, page 4.7

Cryptography: means the discipline which embodies principles, means andmethods for the transformation of data in order to hide its information content,
prevent its undetected modification and/or prevent its unauthorized use(ISO 7498-2).

.8Data: means a re-interpretable representation of information in a formalizedmanner suitable for communication, interpretation or processing(ISO/IEC 2382-1).

.9Digitalcertificate:meansacryptographictransformation(see "cryptography") of a data unit in an asymmetric (public key)
cryptosystem, using a Digital Signature to unite an identity with a public key.

.10

Digital signature: means data appended to, or a cryptographictransformation (see "cryptography") of, a data unit that allows a recipient of
the data unit to prove the source and integrity of the data unit and protect
against forgery e.g. by the recipient (ISO 7498-2).

.11Document: means books, manuals, plans, instructions and similar media
that are not certificates and are used to convey a ship's information.

.12

Electronic record book: means a device or system used to electronicallyrecord the entries for discharges, transfers and other operations as required
under MARPOL Annexes and the NOX Technical Code.

.13

Functional Unit: means an entity of hardware, software, or both, capable ofaccomplishing a specified purpose ISO/IEC 2382-1:1993 Information
technology-Vocabulary- Part 1: Fundamental terms, definition 10.01.40.

.14Graphic character: means a character, other than a control character, thathas a visual representation and is normally produced by writing, printing or
displaying (ISO 2382-4).

.15

IEC 60092 (series): means standards published by the International
Electrotechnical Commission (IEC) on Electrical Installations on Ships.

.16

IEC 60533: means standard published by the International ElectrotechnicalCommission (IEC) on Electrical and Electronic Installations on
Ships Electromagnetic Compatibility.

.17

Offline: means usage #1. Pertaining to the operation of a functional unit
when not under the direct control of the system with which it is associated.
Offline units are not available for immediate use on demand by the system.
Offline units may be independently operated. Usage #2. Pertaining toequipment that is disconnected from a system, is not in operation, andusually has its main power source disconnected or turned off.

.18

Portable Document Format (PDF): means a digital form for representing
documents that enables users to exchange and view electronic documents
easily and reliably, independent of the environment in which they werecreated and the environment in which they are viewed or printed(ISO 32000).

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MEPC 74/18/Add.1
Annex 1, page 5.19

Port: means any port, terminal, offshore terminal, ship and repair yard or
roadstead which is normally used for the loading, unloading, repair andanchoring of ships, or any other place at which a ship can call.

.20

Key: means a sequence of symbols that controls the operation of
encipherment and decipherment (see "cryptography").

.21

Private key: means (in a public key cryptosystem) that key of a user's key
pair which is known only by that user (ISO/IEC 9594-8).

.22

Public key: means (in a public key cryptosystem) that key of a user's key
pair which is publicly known (ISO/IEC 9594-8).

.23

Role Based Access Control (RBAC): means a control mechanism thatprovides different access levels to guarantee that individuals and devices
can only gain access to and perform operations on network elements, stored
information, and information flows for which they are authorized(ISO/IEC 27033-2:2012).

.24

Shipowner: means one who owns or operates a ship, whether a person,a corporation or other legal entity, and any person acting on behalf of theowner or operator.

.25

Signature: means the handwritten means of identifying the signer of adocument or an electronic equivalent which is uniquely and securely linked
to an individual.

.26

Standardized: means the prescription of an authoritative rule, principle,
means of judgement or estimation, criterion, measure of correctness,measure of perfection or some definite degree of any quality that determines
what is adequate for a purpose.

.27

Storage (device): means a functional unit into which data can be placed, inwhich they can be retained, and from which they can be retrieved(ISO/IEC 2382-1:1993 Information technology
VocabularyPart 1:#;Fundamental terms).

4

SYSTEM SPECIFICATIONS

4.1

Ability of the electronic record book to meet regulations under MARPOL

4.1.1
The use and output presentation of any electronic record book approved by an
Administration should satisfy the requirements of all relevant regulations under MARPOL.
4.1.2
As MARPOL specifies the recording of a range of information for specificcircumstances, an approved system should only allow a complete entry to be saved forverification 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 beinstalled 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 beprotected by measures aimed at preventing attempts at manipulation or falsification.
The system should automatically record any attempts to manipulate or falsify any data.

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MEPC 74/18/Add.1
Annex 1, page 6
4.1.3
To assist with consistent recording of data such as dates and positions, the systemshould be developed to display entry fields and request data formats that are as consistent as
possible with other electronic reporting required by IMO and other shipboard systems.
Electronic record books should be presented in the form as specified in relevant
MARPOL Annexes in order to assist the smooth transition from hard copy record books toelectronic ones.
4.1.4
In order to comply with MARPOL requirements, an electronic record book should havethe capability to retain all records made for the minimum period as specified in each Annex of
MARPOL. The capability to produce a hard copy of verified records for the master to certify as
a true copy, upon request from relevant authorities, should also be provided.
4.2

Updates to the electronic record book

As MARPOL and its Annexes continue to evolve, it is essential that all approved electronic
record books are reviewed and appropriately updated to ensure relevant
MARPOL amendments are incorporated in the electronic record book. Any updates should notcause loss of existing records, nor make them unreadable, and the system should continue topresent all records in the form specified by MARPOL. Updates to the system should becompleted prior to the entry into force of the relevant MARPOL amendments.
4.3

Security and accountability of the electronic record book

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, theelectronic 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 eachentry to uniquely identify the user and whether the user provided accessed or amended anentry.
4.3.3
Electronic signatures applied to an electronic record book should meet authentication
standards, as adopted by the Administration.
4.3.4
Records and entries should be protected by measures aimed at preventing anddetecting attempts at unauthorized deletion, destruction or amendment. After an entry is savedby the user, the system should secure the information against unauthorized or untraceablechanges. 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 ina format that makes it clear that the entry has been amended. To create transparency ofchanges to saved or verified entries, it is essential that the system is designed to retain boththe original entry and the amendment(s).
4.3.5
If an entry requires amendment, it is recommended that the reason and user identifier,for the officer making the amendment, be recorded for verification by the master. The original
entries and all amendments should be retained and visible.

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MEPC 74/18/Add.1
Annex 1, page 7
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 masterof 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.
4.3.7
The electronic record book should also be able to log and identify the entries made,amended or verified by time. This will assist in identifying those situations where actions
requiring an entry are undertaken over days or weeks and all entered at one time, where suchan approach to making entries is consistent with MARPOL (e.g. regulation 10 of
MARPOL Annex V requires entries to be "promptly recorded" and "signed for on the date ofdischarge or incineration" by the officer in charge).
4.3.8
To provide for different stages of the data entry and approval process, the electronic
record book should provide a status field for each entry that clearly determines the verification
stage of the entry. For example, when an entry has been saved in the system by the user, theentry should reflect a term such as "pending" or "awaiting verification". Once the master hasverified an entry, a term such as "verified" should be automatically reflected.
4.3.9
If an entry is amended after the master has verified it, the electronic record bookshould automatically return the entry to "pending" or "re-verification" notifying the master thatthe entry requires re-verification.
4.3.10 To ensure that entries are verified in a timely manner, the system should provide areminder that verification by the master is required. It is recommended that where possible,
verifications occur prior to arrival in port. Entries not verified should be accompanied bycomments advising of the reason for non-verification.
4.3.11 If a recorded entry correlates with a receipt for services (such as a receipt received
when waste is discharged to a reception facility), or the endorsement provided during
regulatory surveys or inspections (such as endorsement of the Cargo Record Book),the electronic record book should allow this receipt or endorsement to be identified or attachedto the relevant entry in the system. This receipt can be referenced in the system with a hard
copy receipt or endorsement made available upon request. Alternatively, the receipt orendorsement can be attached to the entry in any form deemed acceptable by the
Administration (such as a scanned copy of the original in PDF), and the original retained.
4.4

Storage of data recorded in the electronic record book

4.4.1
To create the same level of confidence as a hard copy record book, any electronic
record book should form part of the Information Technology Business Continuity Plan.
This includes having an appropriate method for backing up data and data recovery if thesystem were to fail or not be available from the ships' network. Consideration should also begiven to alternate power supplies to ensure consistent access to the system. Both data
recovery and power sources are essential to allow ongoing entries to be made and facilitate
port State control (PSC) inspections.
4.4.2
The electronic record book should have the capability to allow automatic backup ofdata 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 notforgotten by the user.

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4.4.3

The recorded data stored in the offline space should be:.1

developed using cryptography so that unauthorized access to the information
is not possible, and so that once the data has been saved it is in a read-onlyformat with no amendments able to be made to the record (unless done sothrough the application or by a user with the appropriate level ofauthorization);.2

in a format that can be transferred from the point of record to another storage
location. Examples include a local (removable) storage peripheral device,
local and remote network storage;.3

maintained in a format that ensures the longevity and integrity of the record; and.4

in a format that allows output presentation and printing of the record.

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; anddate 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 ofelectronic documents independent of the environment in which they were created and theenvironment in which they are viewed or printed, in a simple way and with fidelity.
4.4.5
An electronic record book and infrastructure related to the system including
computers and peripherals, should be installed in compliance with IEC 60092 and IEC 60533,
where applicable.
5

DECLARATION

5.1
Any electronic system deemed to meet the above criteria should be provided withwritten confirmation by the Administration and carried on board the ship for the purpose ofregulatory surveys or inspections. An example of a declaration can be seen in the appendix.
5.2
Delegating the assessment of the electronic record book against these Guidelines
and the issuing of a declaration on behalf of the Administration by recognized organizations(ROs) is at the discretion of the Administration.
6

MARPOL INSPECTION AND ENFORCEMENT

6.1

Inspection

6.1.1
An electronic record book should have the ability to meet the company
verification/audit requirements (such as integration with the ships Safety Management System(International Safety Management Code)). The record book should also have the ability tomeet all flag State and survey requirements. In addition, an electronic record book should meetall control provisions as set out in the relevant Annexes of MARPOL. Such a system should
also meet any general requirements set out in the Procedures for port State control, 2017
(resolution A.1119(30)), as amended, as well as support the detection of violations andenforcement of the Convention as outlined in Article 6 of MARPOL.
6.1.2
The use of and reliance upon electronic record books in no way relieves shipownersof 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 bookfor verification.
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6.2

Equipment requirements during an inspection

As the electronic record book will be presented using the ships' onboard equipment, it should
not be necessary for officers to carry additional equipment (e.g. electronic devices to view therecords) during inspections. Officers may choose to carry additional equipment on board to aid
in the verification process if the ships' onboard equipment is unavailable.
6.3

Prosecution

To accommodate current procedures when investigating illegal discharges under MARPOL,
the electronic record book should allow for the specific entry, relevant page, pages or theentirety of the electronic record book to be printed at the time of an investigation and eachprinted page physically signed by the master to certify it as a "true copy". All printed pages
should provide the following details in addition to those required under MARPOL for record
books:.1

the title and full name of the person that entered the record (in addition to theperson's unique username and/or ID in the electronic record book);.2

any changes that were made to the entries;.3

the date and time of printing;.4

the name and version number of the electronic record book from which thetrue copy was produced; and.5page numbering and number of pages to ensure the report is complete.

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APPENDIX
EXAMPLE DECLARATIONDECLARATION OF MARPOL ELECTRONIC RECORD BOOK
Issued under the authority of the Government of:(full designation of the country)
In reference to the requirements set out in theInternational Convention for the Prevention of Pollution from Ships (MARPOL)

This is to declare that the electronic system designed to record entries in accordance with
Administration to meet the relevant requirements as set out in MARPOL and is consistent with
the Guidelines developed by the International Maritime Organization (IMO).
Electronic Record Book Manufacturer
Electronic Record Book SupplierElectronic Record Book Installer
Electronic
RecordName/Version

Book

Software

Electronic Record Book is in accordance with
MEPC Resolution/s

Date of installation(dd/mm/yy)
A copy of this declaration should be carried on board a ship fitted with this Electronic Record
Book at all times.

NAME

SIGNATURE

Seal or stamp of the Authority, as appropriate***
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DATE(dd/mm/yy)