The Oil Record Book and magic pipe cases

What goes in Part I

Regulation 17.2 requires an entry, tank by tank where appropriate, whenever any of these takes place: ballasting or cleaning of oil fuel tanks; discharge of dirty ballast or cleaning water from them; collection and disposal of oil residues (sludge), which must be kept in the sludge tanks required by regulation 12;¹² discharge overboard or other disposal of machinery-space bilge water; and bunkering of fuel or bulk lubricating oil. Accidental or exceptional discharges need a statement of the circumstances and reasons (17.3), and any failure of the oil filtering equipment must be recorded (17.5).¹

The book uses letter codes. IMO’s guidance MEPC.1/Circ.736/Rev.2 gives worked examples for codes C to I, the ones used daily:²

The house rules from the guidance

MEPC.1/Circ.736/Rev.2 sets the general rules that port state control officers apply:²

• record operations in the order they were carried out;
• write dates as dd-MONTH-yyyy, for example 16-MAR-2026;
• the officer in charge makes and signs each entry; the master signs each completed page;
• leave no full empty lines between entries;
• strike a wrong entry through with a single line so it stays legible, sign and date it, and write the correct entry after it;
• name tanks exactly as in the IOPP Supplement;
• oily rags and used filters go in the Garbage Record Book only;
• recording bilge water holding tank quantities and general separator maintenance is voluntary.

After a shore disposal (C.12.1), get a receipt or certificate from the reception facility, barge or truck with the quantity, date and time, and keep it with the Oil Record Book. The guidance notes that this receipt “may aid the master” in proving the ship was not involved in an alleged pollution incident.²

Electronic record books

Since 1 October 2020 regulation 17.1 allows Part I to be kept as an electronic record book approved by the Administration taking into account IMO guidelines, with the master’s signature applied to each completed page “or group of electronic entries”.³ The guidelines in resolution MEPC.312(74) expect audit logging that identifies the user against every entry, amended entries shown as amended with the original kept visible, the ability to print a hard copy for the master to certify as a true copy, and a written declaration from the Administration carried on board.⁴ Liberia, for example, publishes a list of the electronic record books it has approved.⁹

Consistency checks: how a false book is found

An inspector does not need to catch a discharge in progress. Records on board are designed to cross-check each other:

• the 15 ppm alarm stores date, time, alarm status and separator operating status for 18 months, so every code D 15.1 or code E 16 overboard discharge should match a period when the separator and alarm were running;¹⁰
• the volume recorded in a D.13 entry should be possible at the separator’s rated capacity in the start and stop times recorded under D.14;
• C.12.3 entries record the incinerator’s running hours, and the weekly C.11 sludge inventory should fall by roughly what was burned or landed;
• C.12.1 entries should match a receipt from the reception facility;
• unexplained gaps (no bilge water generated for weeks on an old ship, a separator that never alarms, a sludge tank that never fills) prompt questions.

Engineers who see a bypass, or are told to make false entries, should know where the law stands: the discharge and the false entry are the crimes, not the refusal, and in the United States the information that leads to a conviction can be rewarded.⁸

What happens to the company

In the US cases the penalties go well beyond the fine. Interorient Marine Services, operator of the Ridgebury Alexandra Z, paid US$2 million and was put on four years’ probation during which every ship it operates calling at US ports had to run an Environmental Compliance Plan.⁶ Princess Cruise Lines paid US$40 million, and ships of eight Carnival cruise brands were put under a court-supervised Environmental Compliance Program with independent audits and a court-appointed monitor for five years.⁷ The ASL Singapore companies were banned from operating in the United States.⁵ Engineers and masters are often charged personally: in the ASL Singapore case the chief engineer pleaded guilty and was sentenced separately.⁵