MARPOL Annex V requirements for the prevention of pollution by garbage from ships are undergoing significant expansion. Amendments adopted at MEPC 79 and MEPC 80, taking effect through 2025–2027, have materially increased the scope and complexity of garbage record-keeping obligations. With MARPOL Annex V deficiencies consistently ranking among the top five most cited categories in Paris MOU, Tokyo MOU, and USCG Port State Control data, the consequences of inadequate documentation — vessel detention, financial penalties, and reputational damage — are both tangible and increasingly common.
What Our Services Cover
The Garbage Record Book remains the primary compliance instrument under MARPOL Annex V, but recent amendments have substantially expanded what it must capture. Our services address the full scope of current and incoming requirements across five key areas.
Enhanced food waste discharge documentation now demands precise recording of discharge locations relative to nearest land, including distance from shore in nautical miles, verification of compliance with the 12-nautical-mile rule, and adherence to 3-nautical-mile comminution requirements within special areas. Our services ensure that discharge events are documented with the specificity now required by enhanced verification protocols, and that special area restrictions are correctly applied across all trading regions.
Expanded plastic waste categorisation, driven by the IMO’s Action Plan to Address Marine Plastic Litter from Ships, introduces separate tracking requirements for single-use plastics, micro-plastic generating materials, fishing gear components, and synthetic rope and netting materials. Our services establish vessel-specific recording frameworks that accommodate these sub-categories and support the IMO’s broader marine litter prevention objectives.
Advanced waste treatment technology documentation is an area of growing complexity. MEPC 80 has recognised emerging technologies including mechanical friction-based systems, thermal hydrolysis units, and advanced dehydration systems, each requiring documentation of operational parameters, residue characteristics, and disposal methods for treated waste products. Our services ensure that Garbage Record Book systems are structured to accommodate these technologies, including vessels operating multiple treatment systems simultaneously.
Port reception facility documentation requirements have been significantly strengthened, now mandating recording of PRF certificate numbers, waste manifest cross-references, photographic evidence where available, and integration with electronic receipt systems. Our services address the historical compliance gap in this area — inadequate PRF documentation has been among the most frequently cited PSC deficiencies — by establishing robust chain-of-custody documentation from waste generation through to final disposal.
Integration with the Ship Energy Efficiency Management Plan is now also required, with waste management efficiency incorporated into the broader environmental performance framework. Our services ensure that Garbage Record Book systems align with SEEMP objectives, including waste reduction strategies and energy consumption records from waste treatment equipment.
Operational Compliance Challenges
Our services are designed to address the persistent operational challenges that drive PSC deficiencies in this area. Regulatory interpretation varies across flag states, port states, and classification societies — particularly regarding new waste treatment technologies and special area boundaries — creating uncertainty for operators across multiple jurisdictions. Crew training consistency and accuracy across shift changes and crew rotations remains one of the most common sources of record-keeping error. Data retention obligations under MARPOL require two years of record accessibility, while modern PSC expectations increasingly demand immediate digital accessibility and extended retention periods. Our services span regulatory interpretation support, crew training frameworks, digital record-keeping system assessment, and audit trail documentation — ensuring that compliance is embedded into operational practice rather than reconstructed at the point of inspection.
Outputs and Deliverables
- Garbage Record Book system review and gap assessment against current and incoming MARPOL Annex V requirements
- Vessel-specific recording frameworks covering all waste categories including expanded plastic sub-categories and advanced treatment technologies
- Port reception facility documentation procedures and chain-of-custody audit trail establishment
- Multi-jurisdictional compliance mapping covering MARPOL special areas, EU regulations, and regional MOU requirements
- SEEMP waste management integration assessment
- Crew training materials and record-keeping consistency protocols
- Digital record-keeping system evaluation and data retention compliance review
- PSC preparation and documentation readiness support
Strategic Value
The regulatory trajectory for marine garbage management points clearly toward continued tightening, with further amendments expected through 2026–2027. Investing in robust, adaptable Garbage Record Book systems now provides both immediate PSC deficiency risk reduction and long-term regulatory security as requirements evolve. Our services ensure that garbage management compliance is embedded into vessel operations as a managed process — not a recurring source of avoidable PSC exposure.
What we do: We provide comprehensive compliance advisory services:
A. Garbage Record Book System Review and Gap Assessment
- Structured review of the vessel’s existing Garbage Record Book system against current and incoming MARPOL Annex V requirements, including MEPC 79 and MEPC 80 amendments effective through 2025–2027
- Assessment of recording completeness and accuracy across all waste categories, identifying gaps relative to enhanced food waste discharge requirements, expanded plastic sub-categories, and advanced waste treatment technology documentation
- Evaluation of alignment with SEEMP waste management integration obligations and special area restrictions applicable to the vessel’s trading pattern
- Delivery of a prioritised gap report with specific remediation actions and a clear baseline from which compliant systems can be established or restructured
B. Vessel-Specific Recording Frameworks
- Development of tailored recording frameworks reflecting the vessel’s actual waste streams, treatment technologies, and trading pattern rather than generic templates that frequently generate PSC deficiencies
- Structured capture of all required waste categories including expanded plastic sub-categories, advanced treatment technology parameters, and residue disposal records in a format practical for crew use across rotations
- Accommodation of vessels operating multiple waste treatment systems simultaneously, ensuring each system’s documentation requirements are clearly addressed within a single coherent framework
- Design emphasis on consistency and usability, directly targeting the crew-level record-keeping errors that remain among the most common sources of Annex V PSC citations
C. Port Reception Facility Documentation and Chain-of-Custody Audit Trail
- Establishment of end-to-end waste chain-of-custody procedures from generation through treatment to final PRF delivery, addressing the most historically deficient area of Annex V compliance
- Standardised procedures for capturing PRF certificate numbers, waste manifest cross-references, and electronic receipt integration consistently across all ports of call
- Multi-jurisdictional compliance mapping covering MARPOL special areas, EU waste regulations, and regional MOU requirements applicable to the vessel’s trading area
- Audit trail structured to demonstrate full compliance at the point of PSC inspection without reliance on reconstructed or retrospective records
D. PSC Preparation and Documentation Readiness Support
- Review of Garbage Record Book entries for completeness and consistency, verifying that records are accessible for the required two-year minimum retention period and meet current PSC accessibility expectations
- Assessment of digital backup and storage arrangements against modern port state control requirements, including electronic record management and cloud storage considerations
- Crew briefing support ensuring personnel can clearly explain waste management procedures and record-keeping practices to inspecting officers
- Targeted preparation across deficiency categories most frequently cited by Paris MOU, Tokyo MOU, and USCG inspections, reducing PSC exposure systematically rather than reactively