“If a person intentionally destroys or mutilates or renders illegible any entry in any statutory log book on ship, he will be liable for a fine or be arrested for destruction of official records”. How often have we come across such disclaimers onboard while maintaining the ships’ official records? Be it the Official Log Book, Oil Record Book or the Engine / Deck Log Books, all have to be maintained in manners that best represent the ship and the owners / managers.
Normally, record keeping is a separate topic discussed in the company’s SMS systems. Some require the vessel to maintain old official records for as long as up to 5 years. Yes, that creates a lot of clutter so to speak, but that’s that. However, since record keeping is of utmost significance and that each event occurring onboard has to be best recorded for all the official and legal intentions, we shall discuss what one has to bear in mind while jotting down the entries in a few important log books.
Here I would like to stress on some of the points that we sometimes miss out while filling up the official logs onboard. This is to bridge the gap for the knowledge we have from our competence / experience at sea and the guidelines provided with each of the log books according to the international regulations.
Official Log Book
The heads of their respective departments are fully and the only ones authorized to maintain this statutory log book and the Master has the overall responsibility to oversee its authenticity and appropriateness. The log book is considered to be a running log of all official events such as Arrival / Departure of the vessel to / from port, Draughts, Freeboards, Onboard Emergency Drills, Crew onboard, Fuel/Fresh Water ROB, Master’s Handing Over/Taking Over, etc. Although some flag states do provide a short guide for keeping the official log book and while some don’t, it is imperative that all entries must be made in a professional and legible manner. A few pointers while making such entries –
- All entries should be made as soon as practicable after an event occurs, since all the logs are running records of the vessel it makes record keeping vulnerable if delayed in entirety.
- Only authorised personnel should make such entries. Master may designate personnel to do so.
- Entries to be signed where required by the person making such entry and by the person witnessing the event.
- All entries must have a date and time recorded
- It will be the Master’s responsibility to ensure the Official log book is accurately filled and signed.
- Entries made in the log must not be amended or deleted under any circumstances unless the Master authorizes the cancellation. If it is to be done, it is a good practice to make sure the entry is stroked out with a single line and an initial put against the omitted entry.
- If the entries cannot be contained within the log books’ pages due to their length, they must be entered separately in a separate document, endorsed and attached to the log book. A reference number may be given for easy record tracking.
Oil Record Book
MARPOL 73/78, Annex I states that each oil tanker of 150 GT and above and every ship of 400 GT and above shall be provided with an Oil Record Book Part I (Machinery Spaces) and each oil tanker of 150 GT and above to carry an Oil Record Book Part II (Oil Cargo Ops). This means the log is a mandatory record of everything related to oil and its handling onboard. This further means that the record will be compulsorily checked by all inspectors / auditors coming onboard for surveys. In fact the log is so closely scrutinised that even a slightest hint of overwriting can be ruinous. Therefore to avoid such mishaps happening, here are a few pointers.
- Firstly, check whether the Oil record book supplied onboard is as per the Convention. Some publications not catering to the forms prescribed in MARPOL have been found onboard while inspection.
- All filling and discharges of oil and oily mixtures to / from the ship’s tanks must be recorded in this log without delay and to the best knowledge known with exact figures and units.
- Each entry of a completed person made must be signed by the officer in charge.
- Without the Master’s signature on each completed page the log book would be considered incomplete and ineligible.
- Make sure the ship’s particulates and oil tank details are correctly filled where required.
- Sometimes, ships have been arrested on the bases of accidental discharges not been recorded appropriately. Even emergency discharges such as cargo jettisoning must be entered into the log book without delay as time permits.
- It is also required to enter details regarding oily mixtures, tank washings, dirty ballast transferred to shore reception facilities along with the time and date of such operation. A certificate or a receipt so provided by the shore facility must be filed onboard and a copy of such receipt may be attached to the log book. This may help the ship ascertain that a legible transfer operation was carried out.
- For operations conducted at sea (considering the MARPOL regulations) such as Crude Oil Washing, Ship-to-Ship Transfer and likewise, it is crucial that the vessel’s precise position is entered in the log book. This will avoid further inquiries should the inspectors suspect any foul play.
Garbage Record Book
Another hot favorite with the inspectors surveying the vessel! This log is to be accurately maintained onboard as per Regulation 10, Annex V of MARPOL 73/78 wherein all garbage disposals, discharges or even accidental losses are recorded. There have been cases where inspectors have been able to point out various ambiguities in the log keeping procedures. Hence, in order to steer clear of such doubts whatsoever the person in charge of the log keeping must ascertain the accuracy of the log is maintained throughout the log keeping periods.
- Each Garbage Record book must be checked for the latest and revised version. The Master and the Person in Charge, in most cases the vessel’s Chief Officer, are responsible for keeping up to the amended international standards.
- The Ship staff must be able to identify different categories of garbage as per the regulations. Plastics, Food Waste, Domestic Wastes, Cargo residues, etc are distinguished into various categories of garbage. So, when the products are discharged or disposed ashore at shore reception facilities, entries must be made in the log book with respect to that particular product only. For example, discharge of Cooking Oil cannot be classified as Food Waste or Cargo Residues cannot be entered as Operational Wastes.
- Most mistakes happen when quantities of discharged garbage entered in the log book are found in vague amounts. The Person in Charge must amount the garbage onboard as per the international requirements and generally measured in cubic meters. During inspection, it has been found that recognizing the accuracy of the amount of garbage discharged or offloaded has not been converted precisely with sundry amounts entered in the log. What’s more, the same mistake has been found to be ‘copied / pasted’ throughout other entries. For example, 0.5m3 of garbage amounts to 500 liters by volume. So, if 500 liters by volume of plastics are disposed ashore every 3 days (assuming the vessel is in port) it calls for a recalculation. Sometimes, entered amount 0.5m3 is mistaken for the actual amount discharged 0.05m3 (50 liters by volume). This is a reason for concern.
- Each entry must be counter signed by the Person in Charge and Master to endorse all the entries for closure.
- Overwriting an entry must be avoided at all costs. It is always recommended to strike the incorrect entry cleanly and provide initials.
- The Ship’s position must be logged down along with the time when garbage was discharged at sea. Care must be taken here that all discharges at sea comply with MARPOL Annex V regulations. It is a good idea to plot the same on the chart for easy reference.
In the next article we will take a look at some more points to be considered while filling three more important record books on ships.