ERB (Electronic Record Books) Archives - SHIP IP LTD

New Requirements for Ballast Water Record Books (BWRBs)

Starting in 2025, the International Maritime Organization (IMO) will implement two resolutions introducing changes to ballast water record-keeping and electronic record book approval. These updates aim to streamline compliance with the Ballast Water Management (BWM) Convention and clarify record-keeping practices for ship operators.

Key Changes Effective 1 February 2025

From 1 February 2025, updated guidelines for ballast water (BW) record-keeping will come into effect, as outlined in Circular BWM.2/Circ.80. These updates are intended to simplify the process for ship crews and include:

1. An updated example of a ballast water reporting form (Appendix II).
2. A voluntary tank-by-tank logging form for ballast water operations.
3. Guidance for logging operations under challenging water quality conditions (from Circular BWM.2/Circ.80/Rev.1).

Additionally, the BWM Convention’s Appendix II has been revised by Resolution MEPC.369(80), introducing a new BWRB format. As of February 2025, all vessels with an approved BWM plan will need to:

• Record ballast water operations using the updated codes (A to H) and item numbers specified in MEPC.369(80).
• Ensure the new BWRB format is used for all record-keeping in compliance with Circular BWM.2/Circ.80.

Crews should become familiar with these changes, as compliance will be required by both port state and flag administrations. Importantly, the BWRB format can be updated without necessitating amendments to the Ballast Water Management Plan (BWMP), meaning no re-approval of the BWMP is expected.

Key Changes Effective 1 October 2025

From 1 October 2025, the use of electronic ballast water record books (e-BWRBs) will become mandatory when replacing hard copy versions. Regulation B-2 of the BWM Convention now permits e-BWRBs, with guidelines for their implementation detailed in Resolution MEPC.372(80). This change includes:

1. Approval of Electronic Record Books: Electronic BWRBs must meet IMO guidelines and receive approval.
2. Ship-Specific Declarations: A declaration must be carried on board to confirm the installation of the electronic system complies with IMO standards. This declaration must be issued by the ship’s flag administration or an authorized body.

Some flag administrations have already approved early implementation of e-BWRBs, allowing ships to transition before October 2025.

Preparing for Compliance

Ship operators should take the following actions to meet the new requirements:

1. Update Record Books: Ensure ballast water record books comply with the new requirements effective from 1 February 2025.
2. Approve Electronic Systems: Verify that any electronic record-keeping system meets IMO guidelines and is approved by the relevant authority.
3. Obtain Declarations: Acquire ship-specific declarations for electronic BWRBs by 1 October 2025 or earlier, depending on flag administration policies.
4. Request Surveys: Schedule surveys to ensure compliance with the new electronic record-keeping requirements, if applicable.

Resources and References

For further information, the following IMO documents and guidelines are recommended:

• MEPC.369(80): Amendments to Appendix II of the BWM Convention (BWRB format).
• BWM.2/Circ.80: Guidance on ballast water record-keeping and reporting.
• MEPC.372(80): Guidelines for the use of electronic record books under the BWM Convention.
• MEPC.383(81): Amendments to Regulations A-1 and B-2 of the BWM Convention regarding electronic record books.

Under the International Convention for the Prevention of Pollution from Ships (MARPOL) and Technical Code on Control or Emissions of Nitrogen Oxides from Marine Diesel Engines (NOx Technical Code 2008), the following software providers have been approved for the listed electronic record books.

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Technical Circular No: 85/2020

IMO vide Resolutions, MEPC.314 (74), MEPC.316 (74), and MEPC.317 (74) has adopted amendments to MARPOL and the NOx Technical Code allowing Electronic Record Books (ERBs) to be used instead of hard copy record books. The amendments will enter into force from 1st October 2020. Associated guidelines for the use of MARPOL ERBs were also adopted vide IMO Resolution MEPC.312 (74).

An Electronic Record Book is a software application designed to replace the traditional paper record books and facilitate accurate entries into an efficient electronic format, while complying with international Conventions and flag State requirements.

ERBs may be used on board to meet the following record book and recording requirements under the MARPOL Annexes and the NOx Technical Code:

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 (ODS) Record Book (MARPOL Annex VI, Regulation 12.6);

Recording of the tier and on or 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 6.2.2.7).

Indian Register of Shipping (IRS) has developed an electronic version of Oil Record Book Part I & Part II in form of a software named “IR Scribe” to enable entries for machinery space operations as well as Cargo/Ballast operations as per Marpol Annex I Reg.17 & 36. “IR Scribe” has been developed taking into the guidelines included in MEPC.312 (74). Marshall Island Flag Administration has approved the “IR-Scribe” for its use on Marshall Island Flag Vessels vide their Marine Notice No. 7-041-5.

When the electronic record book is proposed to be used on board a ship, based on request from Company, the Administration will issue a ‘Declaration of MARPOL Electronic Record Book(s)’ which must be kept on board for presentation to duly authorised officials when requested. The procedures related to the use of ERBs must be documented in the Safety Management System.

Ship owners/ operators are advised to be guided by above..

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ELECTRONIC RECORD BOOKS (ERB) FOR SHIPS,Oil Record Book, parts I and II (MARPOL Annex I, Regulations 17.1 and 36.1)