The first question is not “which software?” but “which book and which approval?”

Evaluate electronic record books under MARPOL and the BWM Convention step by step, from applicable book and flag approval to user verification and inspection output.

Written by: Faromo · Product and maritime domain teamReviewed by: Faromo · Technical and regulatory reviewLast reviewed:

An electronic record book is more than a data-entry screen.

MEPC.312(74) defines electronic-system guidance for Oil Record Books, Cargo Record Books, Garbage Record Books, ODS Record Books and certain Annex VI records under MARPOL. The related MARPOL amendments entered into force on 1 October 2020. MEPC.372(80) and MEPC.383(81) provide a similar electronic option and control framework for the Ballast Water Record Book, with the amendments entering into force on 1 October 2025.

In both cases, an “electronic option” does not mean automatic acceptance or permission to discontinue the paper book. The Administration must confirm that the system meets official requirements, a written declaration must remain onboard, and records, backup and true-copy arrangements must be available to the master, officers and inspectors. Selection should therefore begin with applicability and acceptance planning before a feature list.

Scope and core capabilities

1. Applicability matrix

For each vessel, identify flag, type, tonnage, operation, MARPOL annex, book part and BWM requirement on separate lines. Clearly separate the BWRB, which falls under the BWM Convention rather than MARPOL.

2. Administration approval and version linkage

Confirm that approval is not assumed fleet-wide and determine how it links to the vessel, flag and software version in use. Define where the written declaration will be kept onboard.

3. Book-specific field control

Test official codes, categories and conditional fields rather than relying on free text. For example, verify whether a discharge-at-sea entry can close without position or applicable tank and quantity data.

4. Identity and verification status

Use real accounts to test unique login, role authorization, officer signature, timely master verification and pending, verified and reverification-required states.

5. Amendment and original record

Verify that an amendment does not overwrite original data and that reason, user, time and changed value remain visible. Clarify which signature or reverification is required after correction.

6. Continuity and true copy

Test retention, automatic offline backup, recovery, receipt linkage and inspection output together. Look for person, signature, amendments, print time, product version and pagination in the output.

Workflow

  1. Map the scope: Prepare the fleet-vessel-book matrix and flag instructions.
  2. Assess control gaps: Compare field, identity, signature, amendment, supporting record, retention and output requirements with the product.
  3. Pilot with real scenarios: Test a normal entry, mistaken record, connectivity loss, master verification and PSC output on one vessel.
  4. Transition after approval: Do not discontinue paper until the Administration declaration, SMS procedure, training, backup and inspection access are complete.

Operational outcomes

  • Avoid confusing MARPOL and BWM scope or their entry-into-force dates.
  • Reduce the risk of treating software capability as Administration approval.
  • Expose missing-field, signature and amendment behavior before purchase.
  • Tie paperless transition to an acceptance plan verified with real vessel scenarios.

Frequently asked questions

Is use of a MARPOL electronic record book mandatory?

No. The relevant MARPOL amendments have allowed approved electronic systems as an alternative to paper since 1 October 2020. Electronic use remains subject to the relevant Administration’s approval.

Is the BWRB a MARPOL record book?

No. The Ballast Water Record Book falls under the Ballast Water Management Convention. Amendments for the electronic BWRB option entered into force on 1 October 2025 and still require Administration approval.

Is a product claiming alignment with IMO guidance sufficient?

No. A vendor claim does not replace written approval from the relevant Administration. Applicable book format, conditional fields, user identity, verification, amendments, retention, backup and true-copy output must also be tested on the actual version.

What should be checked in a true-copy output?

Beyond the applicable book content, the person recording and verifying, amendments, output time, product name and version, pagination and required endorsements should be visible. The exact output format must be confirmed with the relevant Administration.

Primary sources