Bulletin 020 – Electronic Record Keeping Systems Rev.1.0

Notice to: Shipowners, Operators, Officers, Flag State Inspectors and Recognised Organisations.

1.             References

a)              Barbados Merchant Shipping Act, 2024

b)              International Convention for the Safety of Life at Sea, 1974, as amended (SOLAS)

c)              International Convention for the Prevention of Pollution from Ships, 1973, as amended (MARPOL)

d)              The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW)

e)              International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention)

f)               Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines (NOx Technical Code 2008)

g)              Resolution MEPC.372(80) Guidelines for the use of electronic record books under the BWM Convention.

h)              Resolution MEPC.312(74), Guidelines for the Use of Electronic Record Books under MARPOL, adopted 17 May 2019

i)                Resolution MEPC.314(74), Amendments to MARPOL Annexes I, II, and V (Electronic Record Books), adopted 17 May 2019

j)                Resolution MEPC.316(74), Amendments to MARPOL Annex VI Electronic Books and EEDI regulations for Ice-strengthened Ships, adopted 17 May 2019

k)              Resolution MEPC.317(74), Amendments to the NOx Technical Code 2008 (Electronic Record Books and Certification Requirements for SCR systems), adopted 17 May 2019

l)                MEPC.369(80) Amendments to the International Convention for the Control and Management for the Ships’ Ballast Water and Sediments, 2004

m)            MEPC.383(81) Amendments to the International Convention for the Control and Management for the Ships’ Ballast Water and Sediments, 2004

n)              Resolution A.916(22) Guidelines for the recording of events related to navigation

2.             Purpose

2.1           This Bulletin outlines the requirements for the use of electronic record keeping systems: MARPOL Electronic Record Books (MERBs), Ballast Water Electronic Record Book (BWERB), and Electronic Logbook Systems (ELSs).

3.             Application

3.1           This Bulletin applies to all Managers wishing to use Electronic Record Keeping Systems on Barbadian vessels.

4.             General

4.1           MERBs, BWERBs and ELSs are permitted to be used on Barbadian vessels subject to compliance with this Bulletin and approval by the BMSR as per Sec. 9 below.

4.2           When switching to electronic record keeping, vessels shall continue to preserve their existing hard copy books for at least three years after the last entry is made, unless otherwise required.

5.             General Requirements for Electronic Record Keeping Systems

5.1           This section details the minimum requirements for any Electronic Record Keeping System and takes into account Resolution A.813(19).

5.2           Arrangements for software replacement, update or upgrade should be effectively implemented under a documented system. The Managers are responsible for ensuring that electronic record keeping systems are maintained to the latest standards required by the BMSR or the relevant international Conventions.

5.3           Where the system can support a client/server installation, the server should be capable of recording client data using multiple workstations simultaneously.

5.4           Minimum Data Reporting & Exporting Requirements:

.1                        The system shall be capable of reproducing records in hard copy (i.e. print out);

.2                        The system shall be capable of producing reports in PDF format;

.3                        Where data export is provided, the system should allow the data to be exported to another system in XML or other internationally standardised format;

.4                        Nothing within the system, or the contractual arrangements between the Managers and equipment supplier, shall prohibit the provision of information to duly authorised officers of an Administration, inspectors, surveyors, auditors, investigators, etc. relating to the discharge of their duties.

5.5           Recording of Entries:

.1                        All users shall have a unique username and password for accessing the system, or another form of login that is unique for each user;

.2                        The identity of the user making entries into the system shall be clearly identified;

.3                        Where automated recording of navigational and machinery events is featured, the electronic deck or engine room logbook or data logger must be able to record relevant events, along with the necessary inputs, in real time.

.4                        All entries shall have a stamp or input with date and time (UTC and local time on board);

.5                        The system shall not allow the deletion of any entries. Any subsequent amendments or corrections to an entry must be clearly identifiable (e.g. by crossing through the original entry with a line) and show the identity of the user making the amendment or correction;

.6                        The system shall be capable of electronically registering the signature or endorsement of the Master and other responsible Officers on all relevant entries;

5.6           Back Up and Recovery of Entries:

.1                       The power supply to the system should be fed from both the main and emergency source of power;

.2                       The system should be capable of making secure copies or backups of the entries to ensure that the information will not be lost if the system fails. The system shall be able to recover data from the copies or backups.

.3                       The system should be able to export all entries to a standard removable storage device, such as a USB memory stick.

.4                       The system shall retain official records for at least the minimum period specified in the relevant legislation or international Conventions as per the guide to retention periods provided in Sec. 12 below.

.5                       Unofficial records shall be retained by the system for the period established by the Managers.

6.             Electronic Logbook Systems (ELSs)

6.1           The minimum requirements for ELS are those of Sec. 5 above and in conjunction with Resolution A.916(22).

6.2           For the purposes of this Bulletin, electronic records are categorised as:

.1                        “Official” records required by the Barbados Merchant Shipping Act or international Conventions and Codes;

.2                        “Unofficial” records that are not required by national legislation or international Conventions and Codes, but are commonly used.

6.3           The following official records may be maintained in an ELS:

.1                        Barbados Official Logbook Part I;

.2                        Barbados Official Logbook Part II (Passenger Ships only);

.3                        Articles of Agreement or Seafarer’s Employment Agreements;

.4                        Data relevant to all seafarers as per STCW Regulation I/14.1.4

.5                        GMDSS Radio Logbook Records required by SOLAS IV/Reg. 17;

.6                        Compass Error Book required by SOLAS V/Reg. 19;

.7                        Records of navigational activities and daily reporting required by SOLAS V/Reg. 28;

.8                        Security Records required by SOLAS  XI-2/Reg. 9.2.3;

.9                        Safety Records required by SOLAS  III/Reg. 19.5.

6.4           The following unofficial records may be maintained in an ELS:

.1                        Deck logbook (also known as Bridge Logbook);

.2                        Engine room logbook;

.3                        Biofouling Record Book

6.5           ELSs used to record official records must capture the information required to be recorded in paper logbooks by the relevant legislation or international Convention.

6.6           Official Logbook Part I & II:

.1                        The Barbados Merchant Shipping Act Sec. 1252 does not specify whether the Official Logbook has to be a hard (paper) copy, only that a logbook is kept and that specific entries are recorded.

.2                        Accordingly, information that is normally recorded in the Official Logbook Part I or Part II may be maintained in an ELS provided that all information required in the relevant sections of the hard copy Official Logbook Parts I & II is recorded.

6.7           Any information in a section of the Official Logbook Parts I & II that is not recorded in an ELS shall be maintained in a hard copy Official Logbook.

6.8           In cases where some information is in a hard copy Official Logbook and some is in an ELS, the hard copy Official Logbook shall contain a statement indicating where the electronically recorded data is stored.

6.9           All sections of the Official Logbook that are maintained electronically must be capable of being printed out in the same layout as the hard copy Official Logbook and exported in PDF format.

6.10       Printed pages must be signed by the Master as a true and complete copy of the corresponding entries in the ELS.

6.11       Articles of Agreement or Seafarer’s Employment Agreements

.1                        Where electronic management of crew articles is enabled, the system should be capable of recording information relevant to the crew list, including the following:

i)           Full name of the crew member;

ii)         Home address;

iii)        Age;

iv)        Place of Birth;

v)         Nationality;

vi)        Passport Number;

vii)      Next of Kin;

viii)     Position on board;

ix)        Certificate of Competency details;

x)         Place and date of embarkation;

xi)        Place and date of disembarkation.

7.             MARPOL Electronic Record Books (MERBs)

7.1           This section outlines the requirements for MERBs that are intended to replace paper MARPOL Record Books.

7.2           The minimum requirements for MERBs are those of Sec. 5 above and in conjunction with MEPC.312(74), MEPC.314(74), MEPC.316(74) and MEPC.317(74)

7.3           The following MARPOL Record Books may be maintained as MERBs:

.1                        MARPOL Annex I – Oil Record Book Part I;

.2                        MARPOL Annex I – Oil Record Book Part II;

.3                        MARPOL Annex II – Cargo Record Book for ships carrying noxious liquid substances in bulk;

.4                        MARPOL Annex V – Garbage Record Book Part I;

.5                        MARPOL annex V – Garbage Record Book Part II;

.6                        MARPOL Annex VI – Record Book for Fuel Oil and Ozone Depleting Substances;

.7                        MARPOL Annex VI – Record of the tier and on or off status of marine diesel engines;

.8                        MARPOL Annex VI – Record of Fuel Oil Changeover;

.9                        NOx Technical Code – Record Book of Engine Parameters;

.10                    EGCS record book (EGCS guidelines).

7.4           MARPOL Annex I – Oil Record Book Parts I & II may be used as MERBs, provided that:

.1                        Entries cannot be deleted;

.2                        Any changes to existing entries are clearly shown, along with the identity or electronic signature of the person who made the change;

.3                        The system is auditable;

.4                        The system is capable of printing records in the Oil Record Book format specified in the Appendix to MARPOL Annex I.

7.5           Printed Pages are to be maintained onboard for the period(s) required by MARPOL Annex I as indicated in Sec. 12 below.

7.6           The MARPOL Annex II – Cargo Record Book for Ships Carrying Noxious Liquid Substances in Bulk may be used as MERB, provided that it meets the following requirements:

.1                        The record follows the recording requirements of MARPOL Annex II;

.2                        Entries cannot be deleted;

.3                        Any changes to existing entries are clearly shown, along with the identity or electronic signature of the person who made the change;

.4                        The system is auditable;

.5                        The system is capable of printing records in the Cargo Record Book format specified in the Appendix to MARPOL Annex II.

7.7           The MARPOL Annex V – Garbage Record Book Part I & II may be used as MERBs, provided that they meet the following requirements:

.1                        The record follows the recording requirements of MARPOL Annex V;

.2                        Entries cannot be deleted;

.3                        Any changes to existing entries are clearly shown, along with the identity or electronic signature of the person who made the change;

.4                        The system is auditable;

.5                        The system is capable of printing records in the Garbage Record Book format specified in the Appendix to MARPOL Annex V.

7.8           The MARPOL Annex VI – Record Book for Fuel Oil and Ozone Depleting Substances may be kept as MERB, provided that it meets the minimum requirements specified in Sec. 5 above.

8.             Ballast Water Electronic Record Book (BWERB)

8.1           This section outlines the requirements for BWERBs that are intended to replace paper Ballast Water Record Books.

8.2           The minimum requirements for BWERBs are those of Sec. 5 above and in conjunction with Resolution MEPC.372(80).

8.3           Resolution MEPC.369(80) updated the Ballast Water Record Book (BWRB) format, with new amendments taking effect on the 1^st of February 2025. Therefore, new BWERBs shall be approved, considering the latest amendments, and all existing approved electronic record books are to be reviewed and appropriately updated to ensure relevant BWM Convention amendments are incorporated in the BWERBs book by the 1^st of October 2025, as per Resolution MEPC.383(81).

9.             BMSR Approval of Electronic Record Keeping Systems

9.1          When Managers select an electronic record keeping system for use on a Barbadian vessel, they shall apply to the BMSR for approval, submitting:

.1                        The Name and IMO Number of the vessel that will have the system installed;

.2                       The system Type Approval Certificate (TAC), or equivalent, issued by a Barbados RO.

.3                        A statement from the Company confirming the following:

i)      The installed system complies with the specific requirements set out in this Bulletin;

ii)     The crew has been appropriately trained in the management, use and operation of the system, in compliance with Regulation I/14.1.4 of the STCW Convention;

iii)   The routines and processes for the conservation and maintenance of the entries in the system comply with relevant requirements and guidance, and procedures for data entry, extraction and retention are incorporated in the Safety Management System;

.4                        A list of logbooks and record books that will have their entries captured in the electronic record keeping system;

9.2          The BMSR may require the Company or the electronic record keeping system vendor to demonstrate the features of the system to ensure that it complies with the requirements of this Bulletin. The BMSR will advise if this is required at the time of application.

9.3          On satisfactory review of the information in Sec.9.1 above and payment of the appropriate fee, the BMSR will issue a Letter of Approval (LoA) for the specific vessel, depending on the electronic record keeping system, including:

.1                        Letter of Approval of Electronic Logbook Systems (ELSs);

.2                        Letter of Approval of MARPOL Electronic Record Books (MERBs);

.3                        Letter of Approval of BWM Convention Electronic Record Book (BWERB).

9.4           Each LoA will list the official records permitted to be stored by the system and shall be kept on board of the vessel using the system, for presentation to duly authorised officials when requested.

9.5           Each LoA is valid for five (5) years from the date of issue and is subject to the vessel being managed by the Company noted on the approval document.

9.6           The Company shall notify the BMSR of any changes to the system or the procedures related to its use in the Safety Management System that affect the LoA.

9.7           The availability of each LoA will be verified at Barbados flag inspections.

10.         Declaration for MERBs and BWERB after a survey

10.1       When installed onboard, a “Declaration of MERB” or “Declaration of BWERB”, as per the Appendices of MEPC.312(74) and Resolution MEPC.372(80), respectively,  shall be issued to the vessel by the RO upon physical attendance and installation survey.

10.2       The declaration serves as proof of meeting the requirements as installed and shall be kept onboard for regulatory surveys or inspections.

11.         Provision of Data to New Managers or Owners

11.1       The international Conventions require certain records to be retained by the ship for specified periods, as indicated in Sec. 12 below.

11.2       Accordingly, Companies using electronic record keeping systems must provide the relevant records to the new Company to cover the required minimum retention period.

11.3       The records may be provided as:

.1                        a PDF or XML file; or

.2                        printed out; or

.3                        in a data format that can be used by the new Company’s system.

11.4       In all cases, the ability to present the records to duly authorised officers upon request must be available on board the vessel.

12.         Minimum Retention Periods for Official Records