An Oil Record Book (ORB) Part I required to be carried onboard ships by MARPOL 73/78,
Annex I, reg. 20. Every oil tanker of 150 gross tonnages and above and every ship of 400
gross tonnage and above, other than oil tanker, shall be provided with an Oil Record Book, Part I (Machinery space operations).
Every oil tanker of 150 gross tonnages and above shall also be provided with an Oil Record
Book, Part II (Cargo/ballast operations).
Owners, masters, and officers are reminded that, in addition to statutory requirements
concerning the maintenance of an ORB, this record is a valuable means of providing proof
that the ship has complied with anti-pollution regulations.
P&I surveyors often noted that this subject does not seem to be either well
defined or fully understood by ships’ officers or MARPOL inspectors.
Clear guidance should be given to ship engineers on how to complete the ORB correctly, especially as per IMO guidelines.
A standard format for entries is adopted by the owner’s ships to avoid the possibility of fines from Port State Control (PSC) or others for incorrect
record-keeping.
A comprehensive listing of machinery space items to be recorded in the ORB is included in
Appendix III of Annex 1 to MARPOL 73/78 as amended.
All entries in the ORB must be in ink. Writing in pencil in any log record should be avoided,
Moreover, all entries should be made at the time of the operation to avoid mistakes.
When making entries in the ORB, the date, operational letter code, and item number should
be inserted in the appropriate columns. The required particulars shall be recorded
chronologically in the blank spaces. The entries in the ORB, for ships holding an IOPP
The certificate should be at least in English, French, or Spanish. Where entries in the official
language of the state whose flag the ship is entitled to fly are also used shall prevail
in case of a dispute or discrepancy.
The ORB should be readily available for inspection at all reasonable times and should be kept on the ship, except in
the case of uncrewed ships undertow. It should be preserved
for three years after the last entry has been made.
Each completed operation should be signed for and dated by the officer or officers in
charge and each completed page shall be countersigned by the Master of the ship.
The ORB contains many references to oil quantity. The limited accuracy of tank measurement
devices, temperature variations, and clingage9 will affect the accuracy of these readings.
The entries in the ORB should be considered accordingly.
The areas of most concerns to the club are the entries required when:
- related to oil residue (sludge and other residues) retained onboard the ship
- transferring or disposing of oil residues
- operating the oily water separator, when non-automatic disposal methods are used
- transferring and collecting bilge water to the bilge tanks and any oil residue (sludge)
content of the bilges
- related to other operations required under Section (I), that is the removal of any bilge or
oily water separator piping or valves for maintenance purposes.
The chief engineer is responsible for ensuring that the ORB is correctly maintained.
Although some companies may delegate this to the second or first engineer, the responsibility
should lie with the chief engineer. The Master, however, should regularly check the ORB
to see that it is correct. The Master is required to sign the ORB after each page is completed. However, a visual check before every port entry is recommended. This important document, if
not accurately completed, can lead to the ship’s Master and chief engineer being fined
or detained.
It should be noted that all entries in the ORB must be wholly genuine and accurate.
Fines for falsifying ORB entries can be greater than $2m and result in imprisonment.
When to make oil record book entry?
The Oil Record Book Part I should be completed on each occasion, on a tank-to-tank basis if appropriate, whenever any of the following machinery space operations takes place in the ship:-
Ballasting or cleaning of Fuel oil tanks
- Discharge of dirty ballast or cleaning water from Fuel oil tanks
- Collection and disposal of Oil residues (Sludge and other Oil residues)
- Non-automatic discharge overboard or disposal otherwise of Bilge water in the machinery space
- Automatic discharge overboard or disposal otherwise of Bilge water in the machinery spaces
- Condition of the Oil Filtering Equipment
- Accidental or other Exceptional discharges of Oil
- Bunkering of Fuel and Bulk Lubricating Oil
- Additional operational procedures and general remarks
Each operation described above needs to be fully recorded without delay in the Oil Record Book Part I. All entries in the book appropriate to that operation are completed.
Entries in the Oil Record Book are to be made under Regulation 17 of Annex I of MARPOL 73/78, as demonstrated in Appendix III of Annex I of MARPOL 73/78, Form of Oil Record Book, OIL RECORD BOOK PART I Machinery space operations, (All ships)
When making entries in the Oil Record Book, the date, operational code, and item number shall be written in the appropriate columns, and the required particulars shall be recorded chronologically in the blank spaces.
Each completed operation shall be signed for and dated by the Officer-In-Charge (As per section 3.0).
Each completed page shall be signed by the Master of the ship.
The Oil Record Book contains many references to oil quantity.
The limited accuracy of tank measurement devices, temperature variations, and list and trim will affect the accuracy of these readings. The entries in the oil record book should be considered accordingly.
Arrangement Plan of Fuel Oil and Bilge Tanks
Entry (in the Oil Record Book preface) of the arrangement plan and capacity of each Fuel Oil Tanks and Bilge or Sludge Handling Tanks shall match exactly that mentioned in the IOPP Certificate Supplement Form B.
Distinguishing between Bilge and Sludge
Although distinguishing between Bilge and Sludge is difficult for onboard handling,
a Shift to/from and Discharge from the Bilge tank shall be treated as Bilge handling.
A shift to/from other Sludge tanks and similar tanks, which is described in the supplement of IOPP certificate or incineration of the content of these tanks, shall be treated as Sludge handling.
Problems with falsified entry in oil record book part 1
US authorities are very particular about matching the amount of sludge incinerated with
the amount of oily water generated, be careful to fill in the Oil Record Book neatly making sure that the
numbers ‘added up’ to avoid fines in USA.
The Act to Prevent Pollution from Ships (APPS) is the US version of MARPOL. It is both a civil and a criminal violation under APPS
and domestic US law to falsify an Oil Record Book intentionally. If the entries are intended to hide discharges of oily wastewater, for
example, bypassing the oily water separator can be very severe. The vessel-operating company can be fined millions
of dollars, and the individuals involved can be sent to prison. It is also a crime called obstruction of justice to lie to a US Coast Guard
inspector. Any intent to hide illegal discharges can be treated as criminal cases. The ORB entry should include any discharge to the reception facility / included the incinerator use.
Guidance for Entries in the ORB Part 1 &
Environmental Compliance procedures
- Dates should be entered in dd-MONTH-yyyy format, e.g. 12-MAR-2020;
- Incineration or landing ashore of oily garbage and used filters should be recorded in the Garbage Record Book only;
- All Entries are to be made and signed by the officer or officers in charge of the operations concerned. The Chief Engineer is to review the ORB daily and verify/countersign each entry. Each completed page shall be verified and signed by the Master of the ship;
- There must be no empty lines between successive entries;
- If a wrong entry is made in the Oil Record Book (ORB), it should be struck through with a single line in such a way that the wrong entry is still legible. The wrong entry should be signed and dated, with the new corrected entry following;
- Tank names and capacities must be recorded exactly as per the entries in the International Oil Pollution Prevention Certificate (IOPPC). The tanks and capacities in the IOPPC should also be checked to ensure they are correct as per the capacity plan and the actual tanks onboard - there have been several observations due to the mistakes made by a class in the IOPP supplement.
- Although the recording of quantities retained in bilge water holding tanks listed under section 3.3 of the IOPPC is voluntary, it is recommended to be recorded within the ORB.
- The recording of general maintenance of items relating to the OWS is also voluntary
- All MARPOL equipment and spares tagged as “critical” within the PMS are to be kept aligned with the Critical Equipment List and ”Minimum Critical Spares Inventory” approved by the Fleet Superintendent.
-
It should be noted that USCG and PSC inspectors are now downloading data from the Oil Content Meters (OCM). This data is compared with the ORB entries, so times entered in the ORB must be accurate.
-
All MARPOL / “Magic Pipe” prosecutions in the USA have been successful based on false or inaccurate entries in record books (Oil, Garbage, Ballast & VGP), NOT THE ACTUAL ILLEGAL DISCHARGE.
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