What Is Actually Permitted
In 2019 the IMO adopted Resolution MEPC.312(74), Guidelines for the Use of Electronic Record Books under MARPOL, and associated amendments took effect from 1 October 2020. Together they establish that an electronic record book may be used in lieu of a hard-copy record book for the applicable MARPOL record-keeping requirements.
Two conditions ride along with that permission, and both matter:
- The system must meet the standards set out in the guidelines — principally around authentication, tamper-evidence and the ability to produce records for inspection.
- The flag Administration must issue a Declaration of MARPOL Electronic Record Book, carried on board.
"Electronic" here means a recognised statutory record, not a spreadsheet or a scanned PDF of a paper page. A well-intentioned digital process that lacks the Declaration is not compliant — it is an unofficial copy alongside a paper book you still have to keep.
Which Record Books Can Go Electronic
| Record book | MARPOL basis | Typically applies to |
|---|---|---|
| Oil Record Book Part I (machinery space) | Annex I | Ships 400 GT+; oil tankers 150 GT+ |
| Oil Record Book Part II (cargo/ballast) | Annex I | Oil tankers 150 GT+ |
| Cargo Record Book | Annex II | Ships carrying noxious liquid substances in bulk |
| Garbage Record Book Parts I & II | Annex V | Per Annex V applicability |
| Ozone-Depleting Substances Record Book | Annex VI | Per Annex VI applicability |
| NOx Technical Code records | Annex VI / NOx Code | Engines subject to the NOx Technical Code |
Beyond MARPOL, many operators also digitise non-MARPOL logs — deck and engine log books, ballast water record books and similar. Those follow their own regulatory routes and flag acceptance; do not assume a MARPOL Declaration covers them.
The Declaration — the Piece People Miss
This is where rollouts most often go wrong. The Declaration of MARPOL Electronic Record Book is issued by the flag Administration, not by the software vendor and not by class. Practical consequences:
- It is flag-specific. A fleet under three flags may face three different processes, timelines and conditions.
- It must be on board. A PSC officer will want to see the Declaration before accepting electronic records — treat it like any other statutory certificate.
- Vendor "type approval" is not the same thing. A class-issued type approval of the software is useful supporting evidence, but the Declaration is what authorises your ship to use it.
- Conditions may be attached — for example on backup, contingency procedures, or how records are produced during inspection.
Sequence the project accordingly: confirm the flag route before the fleet-wide rollout, not after the software is installed.
Technical Standards a System Must Meet
The intent of the guidelines is that an electronic record must be at least as trustworthy as a properly kept paper one. In practice that means:
| Requirement | What it means in the product |
|---|---|
| Secure authentication | Individual user accounts — entries attributable to a named officer, not a shared login |
| Tamper-evident records | Entries cannot be silently altered or deleted; timestamps reflect when the entry was made |
| Audit trail of amendments | Corrections recorded as corrections — original value, new value, who, when, why |
| Production for inspection | Records can be displayed and produced on demand during an inspection |
| Backup and integrity | Records survive hardware failure; retention for the required period |
| Offline operation | Works with no connectivity — statutory records cannot depend on satellite availability |
| Contingency | A defined procedure if the system fails, so recording continues |
Offline capability is the one to press hardest on. A cloud-only record book that needs a live connection to write an entry is unfit for purpose at sea. Ask to see an entry created with connectivity disabled, and then synchronised.
Paper vs Electronic: an Honest Comparison
| Paper | Electronic | |
|---|---|---|
| Code selection errors | Common — relies on memory | Largely eliminated by guided entry |
| Missing quantities/tanks | Common | Prevented by mandatory fields |
| Retrospective entries | Possible, and visibly so | Structurally prevented by timestamps |
| Balance reconciliation | Manual, drifts over time | Calculated automatically |
| Legibility & retrieval | Handwriting; slow retrieval | Instant, legible, searchable |
| Inspector familiarity | Universal | Improving, but varies by port/inspector |
| Failure mode | Physical loss or damage | Hardware/software failure — needs contingency |
| Up-front effort | None | Flag Declaration, install, crew training |
The honest summary: electronic record books remove the systemic error categories that cause most deficiencies, and add a smaller set of manageable risks (approval admin, hardware dependence, inspector familiarity). For fleets where ORB findings recur, the trade is usually strongly favourable — but it is a trade, not a free win.
Evaluating a Vendor: 10 Questions
- Which MARPOL record books does the system cover, exactly?
- Can you show entries being made fully offline, then synchronising?
- How are corrections handled — is the original value preserved and visible?
- Are entries attributable to individual users, with Master approval workflow?
- Are running balances calculated and carried forward automatically?
- Which flag Administrations have accepted this system, and can you support our registry?
- Is there class type approval, and what is its scope?
- How are records produced during a PSC inspection — on screen, printed, exported?
- What is the backup and retention model, and what happens on hardware failure?
- Does it integrate with the systems the records must reconcile against — soundings, maintenance, bunkering?
Question 10 is the one operators under-ask. The value of a digital record book multiplies when it shares data with the rest of your operation rather than becoming another silo — see our Oil Record Book guide for the cross-checks inspectors actually perform.
Rolling It Out Without Drama
- Confirm the flag route first. Understand the Declaration process for every flag in the fleet before selecting.
- Pilot on one or two ships for a full cycle, including at least one PSC inspection if possible.
- Run parallel briefly if your flag or risk appetite requires it — then stop; indefinite dual running defeats the purpose.
- Train per rank and per rotation. The relief engineer needs the same onboarding as the incumbent.
- Write the contingency procedure into the SMS and test it.
- Brief the ship on demonstrating it — a crew that can show an inspector the records and the Declaration in two minutes avoids most friction.
See a guided electronic Oil Record Book in practice
Volaxin's electronic record books apply the correct code, enforce quantities and tanks, calculate balances and keep a tamper-evident trail — fully offline on board. Book a demo and we'll map the flag-Declaration route for your registry.
Request a DemoFrequently Asked Questions
What is an electronic record book?
A digital system used in lieu of a hard-copy statutory log book, permitted under IMO Resolution MEPC.312(74) where it meets the required standards and the flag has issued a Declaration.
Which books can go electronic?
Oil Record Book Parts I and II, Cargo Record Book, Garbage Record Book Parts I and II, Ozone-Depleting Substances Record Book and NOx Technical Code records.
What is the Declaration of MARPOL Electronic Record Book?
A flag-issued document confirming the system is accepted for the applicable record-keeping. It must be carried on board and is what PSC will ask to see.
What standards must the system meet?
Secure authentication, tamper-evident timestamps, a full audit trail of amendments, production of records for inspection, reliable backup, and offline operation.
Is it accepted everywhere?
Acceptance flows from the flag Declaration, but inspector familiarity varies — carry the Declaration, be able to demonstrate the system quickly, and keep a contingency procedure.
Scope & Sources
This guide summarises publicly available material on IMO Resolution MEPC.312(74) and MARPOL electronic record-keeping. The regulation text and your flag Administration's guidance take precedence. Applicability, conditions and acceptance vary by Administration and evolve over time — verify before acting. Nothing here constitutes legal or classification advice.