Electronic LogBook when Environment meets Efficiency
From 1 October 2020, IMO adopted amendments to MARPOL Annexes I, II, V, VI and the NOx Technical Code have entered into force, enabling the use of Electronic Record Books (ERBs) as an alternative to paper record books.
As always MARPOL work is towards the reduction of pollution, and the increasing focus of companies and shipowners on ways to operate in an environmentally responsible manner pass also through reducing the heavy burden associated with paperwork via electronic means.
The regulation has therefore enabled the electronic recording of:
- 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 184.108.40.206).
Electronic Record Books should be developed in accordance with IMO Resolution MEPC.312(74).
In the introduction to the regulation is also interesting to note how MARPOL is encouraging all the various stakeholders to embrace the digitalization of record books, as this may have many benefits for the retention of records by companies, crew and officers.
“Is public knowledge of how valuable data is nowadays, and thinking about the amount of information produced by each vessel every day, it’s disarming how little we do with it…“
It is expected that as companies and shipowners increasingly explore electronic record keeping, flag State Administrations will be requested to approve electronic recording systems. This guidance aims to provide standardized information on supporting an electronic record book to ensure the obligations of MARPOL are met and that there is a consistent approach to approving such systems.
Let’s, therefore conclude that administrations won’t pose resistance but will, on the contrary, facilitate the adoption of electronic logbooks.
Nevertheless, the MEPC.312(74) gives detailed requirements of how your system should operate.
Below we try to summarize the various areas of such requirements:
A.Completeness of information.
Is made very clear that logbook must be compiled in every part before information could be approved by the Master and therefore saved.
B. Security and Accountability
The regulation doesn’t leave any doubt when it comes to the fact that everything has to be transparent and recorded. Information will need to be always approved, changes will be possible, but must be documented, tracked and comparable to the original log.
C. Safely stored and always available
Your system must always be available when required and therefore be part of the Information Technology Business Continuity Plan.
To enforce this last point MARPOL specifies that 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.
“…MARPOL is clear when saying that failure to present the data is not an option…“
The maritime industry has spent much of the last few years speaking about autonomous ships while many ships still lack the basic automation that could reduce workload, increase reporting accuracy and deliver data in a legible, indexed and searchable form. For most of the shipping companies, the cost of entry to the digitalized world has been a barrier. Six- and seven-figure penalties for falsifying or failing to maintain an accurate oil record book have become all too common in recent years, but a digital logbook could quickly solve all of this.
It is no brainer that shipping companies could and should utilize these new regulations, not only because of the objectives they have been designed for, but also to boost new levels of efficiency and cultural changes within their organization.
Is public knowledge of how valuable data is nowadays, and thinking about the amount of information produced by each vessel every day, it’s disarming how little we do with it, just because we don’t store it in the right format. Here is an excellent occasion to improve your business and the industry in general.
What is the safest way of transitioning?
Let’s be clear; changes are often complicated, and a ponderate approach is always the suggested way.
The first step in every thinking processes should always be to understand the objectives. Do we want to implement eLogbooks to reduce the workload on the crew, to reduce human mistakes, to rise company profile or to get rid of a process that seems so archaic?
Answering the above question should guide you towards an automated logbook or a digital manual form. The latter could be achieved using standalone products and at a relatively lower price, while the former will imply a higher cost to link multiple systems but will return the highest value in terms of efficiency and ultimately of the overall business.
“…changes are often complicated, and a ponderate approach is always the suggested way.”
A second suggestion is to make sure always to have a plan B, MARPOL is clear that failure to present the data is not an option, test your new solution perhaps on a couple of pilot vessels while running the paper-based process at the same time. Remove the traditional logbook when you are satisfied, but keep on running the pilot little longer.
When you will be gone through a large sample of scenarios, and you have tweaked the solution couple of times (that will happen, I promise you!) only then you will be ready to roll it out to the rest of your fleet.
We highly suggest checking with your ERP supplier what options are available for your system and how they can ultimately support your objectives, but remember to research the market as well, because a wrong decision may put you back of months and several thousand dollars.
sources for this article:
IMO, MARPOL, standard-club.com, Dromon
Posted by Antonio Fiorillo