Electronic Oil Record Books: questions answered

Direct answers on the legality, inspection, signing, and offline operation of electronic Oil Record Books under MARPOL Annex I and IMO MEPC.312(74).

These answers cover the questions ship operators, officers, and inspectors ask most often about electronic Oil Record Books. Each cites the MARPOL Annex I regulation or IMO resolution it rests on. For the detail behind any of them, see the compliance page or contact the compliance team.

Is an electronic Oil Record Book legal under MARPOL?

Yes. IMO Resolution MEPC.312(74), adopted 17 May 2019 and in force since 1 October 2020, lets an electronic record book replace the paper Oil Record Book that MARPOL Annex I requires. The vessel's flag administration has to accept the electronic system, and the system has to meet the resolution's requirements for data integrity, signing, audit, and inspection access.

What does MEPC.312(74) require of an electronic record book?

It requires the system to protect entries against unauthorized change, record who made each entry and when, hold a complete audit trail, let an inspector read and export entries on board, and retain records for the period MARPOL sets. ShipORB meets these with SHA-256 hash chains, ECDSA P-256 signatures, role-based access per the resolution, and offline export.

Can a Port State Control officer inspect a digital ORB?

Yes, and the inspection works fully offline on the vessel. A PSC officer views, filters, and exports entries on a LAN device in minutes, sees the full Created, Reviewed, Verified trail on each entry, and can re-run the hash-chain check independently. ShipORB exports an IMO-format PDF for any date range with a verification stamp on every page.

Does the Master still have to sign each completed page?

Yes. MARPOL Annex I Reg.17 for Part I and Reg.36 for Part II require the Master to sign each completed page of the Oil Record Book. ShipORB treats a page as a fixed block of 25 entries, the same lines-per-page as the paper form, and refuses to close a book while any page that carries entries is still unsigned.

What happens to ORB entries when the vessel has no internet?

Everything keeps working. ShipORB is offline-first: officers create, review, verify, and sign entries against an encrypted on-vessel database with no network connection. When the satellite link returns, entries sync to shore on their own. A vessel can stay offline for weeks and lose nothing.

Which vessels must keep an Oil Record Book?

Under MARPOL Annex I, every ship of 400 gross tonnage and above keeps Oil Record Book Part I for machinery-space operations, and every oil tanker of 150 gross tonnage and above also keeps Part II for cargo and ballast operations. An oil tanker above both thresholds keeps both parts.

How long must Oil Record Book records be kept?

MARPOL Annex I requires the Oil Record Book to stay on board and available for inspection, and to be retained for three years after the last entry is made. ShipORB preserves the full signed record across that period, and links each closed book to the next with a continuity hash so the chain holds across book changes.

Can a verified entry be edited or deleted?

No. Once an entry is verified it is locked into the SHA-256 hash chain; changing a single byte breaks the chain and the verification check flags it. A correction is made as a new amendment entry linked to the original, and both are kept, which matches how corrections work in the paper book.

What is the difference between ORB Part I and Part II?

Part I records machinery-space operations such as fuel and bilge handling, oily-water separator use, and sludge disposal, and applies to ships of 400 GT and above. Part II records cargo and ballast operations and applies to oil tankers of 150 GT and above. A tanker keeps both.

Does an electronic ORB need class society approval?

The flag administration accepts the electronic system under MEPC.312(74), and class societies issue type approval against that framework; DNV does so under Type Approval Programme No. 1-433.20. New vessels also fall under IACS UR E26 and E27, the cybersecurity requirements that apply to ships contracted for construction on or after 1 July 2024 and cover onboard software like an e-ORB.

What happens if the electronic system fails during a voyage?

The crew switches to a paper Oil Record Book at once, notes the date and time of the switch, and enters the paper records into the electronic system after it is restored, with an entry that documents the gap. The encrypted database lives on the vessel, so a lost satellite link is not a system failure and needs no fallback.

Have a question that is not here?

Talk to the compliance team about MEPC.312(74), flag-state acceptance, or PSC readiness for your fleet.