REGULATORY FOOTING
What LOOP may lawfully be, and what it isn't
LOOP can serve today as the unofficial machinery log under 46 CFR 97.35-3 and as a due-date tracker for the recurring tests in 46 CFR 97.35-5 and 46 CFR Part 61, and it can help produce ISM objective evidence under 33 CFR 96.120 — though the "attributable" half of that bar waits on per-user login aboard, which is in build. It is not an accepted MARPOL electronic record book, it does not replace the CG-706 Official Logbook or the PMS, and its shipboard record layer is mutable today.
What LOOP may lawfully be today
Three footings LOOP can stand on today, plus one piece of statutory context. None of them involves an approval regime: US-flag rules leave the format of the unofficial machinery log open, and ISM objective evidence has no acceptance or type-approval scheme at all — the bar is evidence that is verifiable, attributable and dated. That middle word, attributable, is where LOOP is not finished, and it is stated plainly further down this page.
- Unofficial machinery log, 46 CFR 97.35-3: may be kept in any preferred format, kept aboard at least a year, produced to marine inspectors on request. LOOP can lawfully serve as this today. Retention and production to inspectors remain the operator's obligation.
- Recurring required tests, 46 CFR 97.35-5 and 46 CFR Part 61: pre-departure steering, whistle and comms; weekly and semi-annual emergency power; monthly cargo gear; fuel received; periodic machinery and automation tests. Carried as templated, due-dated assignments from a versioned round builder. LOOP flags what is due; it does not certify that a test was performed.
- ISM objective evidence, 33 CFR 96.120: no approval regime exists, and the bar is verifiable, attributable, dated evidence. LOOP produces dated, reviewable records today, so treat its output as an aid toward objective evidence rather than finished evidence — the attributable half waits on per-user login aboard. in build
- Context, not a footing: 46 USC 11304 (LoBiondo Act, 2018) says official logbook entries may be in any form, including electronic. That removed the paper-only assumption in principle. It is not an acceptance of any product, and LOOP does not keep the Official Logbook.
- All of it runs with the link down: Android tablets, a Windows hub, a Raspberry Pi engine-room display, a local Isar database, and an AI assistant that runs on the ship. No connectivity is required for any core function. shipped
What LOOP is not
These lines matter more than the feature list. Each one is a place where an operator could get hurt if the tool were oversold, so they are stated before anything is sold. If anyone presenting LOOP tells you otherwise, they are wrong and this page is the reference.
- Not an accepted MARPOL electronic record book. That requires USCG acceptance under NVIC 01-23 via an ACS attestation to IMO Res. MEPC.312(74). LOOP has not taken that path and is not on it. not planned
- Does not replace the CG-706 Official Logbook. Not legally possible today. The Official Logbook stays as it is, with the Master.
- Does not replace the PMS. NS5 remains the maintenance system of record, and LOOP has no connection to it today — the maintenance date-tracker board on the Pi display was seeded by hand from the vessel's own whiteboard using NS5 intervals. A one-way, read-only NS5 bridge with a human in the loop is next. in build
- Not an inventory, procurement or crew-management system. There is no rest-hours module aboard today; that one is on the roadmap. in build
- No savings, ROI or payback figure is claimed on this page, because none has been measured on a hull. If a number ever appears here it will be labelled modelled, with the assumption shown next to it.
Record integrity: the blunt version
Attributable, but not yet tamper-evident. Per-user sign-in is aboard: a crew member taps his own name, and where a PIN is set on that account the app asks for it. Readings are filed under the user who was signed in, and completed jobs carry who closed them and who approved them. What attribution does not yet survive is scrutiny: readings are filed under the user in the storage key rather than inside the record, so trends, alarms, consumption and the engine log read back anonymous; an account with no PIN set signs in on one tap; and the hub's round-data endpoint accepts a submission from anywhere on the vessel LAN without checking the session, so a reading can be filed in another person's name. The record layer underneath is mutable and capacity-capped. Until the append-only signed store lands, LOOP data should not be relied on as a documentation trail: use it as an operating tool, as the unofficial machinery log, and as shore visibility between port calls, and keep the statutory records exactly where they are. The signed store is the current build priority, ahead of every new feature.
- Today: entries are editable and local storage has a capacity ceiling. No hash chain, no per-entry signature. No immutability and no tamper-evidence is claimed. shipped, as described
- Append-only, hash-chained, per-entry signed record store. in build, current priority
- Per-user named login aboard, so that attribution can mean something under 33 CFR 96.120. Sign-in, roles and capability-gated screens are aboard now; what remains is the part that makes attribution hold — a PIN required on every account, session checks on the hub's round-data and crew endpoints, and the recorder carried inside the record instead of in its storage key. shipped in part
- True-copy PDF export and incident/survey evidence bundles, which depend on the two items above. in build
- Until those land, treat weekly reports and TSV exports as working documents, not as evidence.
Defect record shape: recorded, then acknowledged ashore
The shape worth copying is simple. A defect is recorded aboard with date, equipment and condition, then acknowledged by the office, so the file shows that shore knew and what was decided. LOOP does part of that today — worklist states, photos and email approve/reject — and the explicit acknowledgement field and the exportable register are in build. SIRE 2.0 rewards this shape, but SIRE 2.0 is an OCIMF tanker inspection regime and does not bind a US-flag container ship. It is referenced here for record shape only, and no SIRE compliance is claimed or implied.
- Today: worklist items carry priority, photos, pending-review and pending-approval states, soft delete with restore, and email-based remote approval where a shore link exists (shore replies APPROVE or REJECT). shipped
- Defect lifecycle with explicit shore-acknowledgement fields, and an exportable open-defect register. in build
- Contractor and riding-squad handoff pack, same record shape, scoped to a job. in build
- SIRE 2.0 is a tanker instrument. This fleet is US-flag container. The regime is cited as good practice, never as an applicable standard, and nothing here is a vetting claim.
What is actually installed and reporting
One hull. The reporting vessel sends roughly two small documents a day, typically under 5 KB, over an opportunistic link. The other sister hulls appear on the shore dashboard with demo data, labelled as demo on the page itself. Sister-ship deviation bands need at least three hulls reporting real data and only one does today, so those bands stay on the roadmap. [in build]
- Capture: template-driven rounds, 16 element types (numeric readings, paired IN/OUT, pass/fail, sliders, multi-select, datetime, media, notes, headers, ranges), inline alarm evaluation as readings are entered, trends with sparklines, computed metrics with unit conversion, equipment groups with running, standby and hibernation states and changeover capture. shipped
- Daily rollup: rounds compliance today and over seven days, worklist stats, alarm state, about 20 headline trends with 30-day series and 2-sigma anomaly counts, consumption rates (fuel t/day, cylinder LO L/day), plant changeovers, equipment status, recent notes, up to eight compressed issue photos, a 0-100 readiness score with component breakdown, and an AI context digest. shipped, one hull
- Shore dashboard, password-protected: fleet league table, rounds and worklist comparison tables, per-vessel readiness dial and component breakdown, a needs-attention panel, this-ship-vs-class charts, the issue-photo grid, and a live Windy map carrying AIS positions with 24-hour dead-reckoned tracks. The league table and comparison tables rank plants and vessels, never people.
- Live AIS: three of the five hulls have been seen reporting real positions.
- The crew sees exactly what shore sees — same rounds, same trends, same readiness breakdown. No individual scoring, no timing of watchkeepers, no use in appraisal. Sign-in aboard exists for record attribution under 33 CFR 96.120, not for measuring people, and the rollup that goes ashore carries counts and one name — whoever took the most recent round, not for performance. This is a union-crewed US-flag fleet and the tool is built for the plant, not the people.
What is shipped, and what is not
This table is the point of the page. It is written to be read by a sceptic, and it is kept honest deliberately — every claim here is checkable against the running system.
| Capability | Status | Note |
|---|---|---|
| Unofficial machinery log, 46 CFR 97.35-3 | Shipped | The rule leaves the format open, so LOOP can serve as this today. Retention aboard for at least a year and production to inspectors stay the operator's obligation, and the store is mutable, so treat it as the working log it is. |
| Recurring required-test tracking, 46 CFR 97.35-5 and Part 61 | Shipped | Tests carried as templated, due-dated items from versioned draft and published templates. The intervals come from the regulation; the tracking is ours. It flags what is due. It does not certify that a test was performed. |
| Full offline operation | Shipped | Tablets, Windows hub, Pi engine-room display, local Isar database, on-ship AI assistant. Nothing in the core capture loop needs the satellite. Shore-side features — email approval, the daily rollup — need a link when one is there. |
| Digital engine log, Form 629 view | Shipped | The field mapping is partial — about 230 of roughly 425 boxes are fed from round data; the rest are not collected by the rounds and print blank. It is a view, not a finished Form 629 substitute, and it is not offered as one. |
| Append-only, signed, tamper-evident record store | In build | Current build priority, not a present capability. Today the shipboard record layer is mutable and capacity-capped. Until this lands, do not rely on LOOP data as a documentation trail, and do not let anyone tell an auditor otherwise. |
| Per-user named authentication aboard | Shipped in part | There is no ship-side per-user login today, so per-reading attribution is not meaningful. This is what gates the word attributable in 33 CFR 96.120. |
| Defect lifecycle with shore acknowledgement, open-defect register export | In build | Worklist states, photos and email approve/reject exist today. The explicit shore-acknowledgement field and the exportable register do not. |
| True-copy PDF exports, incident and survey evidence bundles | In build | Blocked behind the signed store and named login. Today there is TSV export and a weekly report with AI summaries; both are working documents, not evidence. |
| MARPOL electronic record book acceptance, NVIC 01-23 / MEPC.312(74) | Not planned | No ACS attestation sought, no USCG acceptance held, no plan to seek one. Keep the approved oil record book and garbage record book exactly as they are. |
| Replacement for the CG-706 Official Logbook, the PMS, inventory, procurement or crew management | Not planned | Legally impossible for the CG-706. Out of scope for the rest. NS5 stays the maintenance system of record; the NS5 bridge in build is read-only, one way, human in the loop. |
What this is not
For a DPA, a vetting inspector or an auditor, the short version is this. LOOP is not a compliance product. It holds no USCG, class or ACS acceptance of any kind, it does not make a statutory record for you, and today it cannot prove who entered a reading or that a reading was not changed afterwards: the record layer is mutable, the recorder is held in the storage key rather than in the record, and the hub accepts round data from the vessel network without a session check. It is a single-hull pilot written by one sailing engineer and it has not been audited by anyone: one hull sends real data, the four sisters on the dashboard are demo data, and the weekly AI summaries are model-written and need a human read before anybody forwards them. What it is: an unofficial machinery log kept in a permitted format, an aid toward ISM objective evidence, a due-date tracker for recurring required tests, and a way for the office to see the plant between port calls. Anything claimed past that is past what the current build can support.