Back in 2013 I took three hits because of ORB. I posted about it here: U.S.C.G. Oil Record Book Noncompliant with MEPC187(59)
The first was from PSC in Japan because C11.4 entries were being made but the instructions from the CG in the ORB did not call for them. So we stopped using the C11.4 entry
The second was a few weeks later from the so-called German Water Police because the C11.4 entries were not being made, paid two 35 euro fines, one for me and one for the chief.
The third hit was from the company complaining that we’d gotten nailed on the ORB twice in a row and they told us to get our shit together.
So I know about problems with the ORB. But my view is it’s far better to take a take a hit on the ORB with no problems elsewhere then have problems with oil in the wrong place. I’d rather eat a shit sandwich then go to jail.
Of course it’s best if all the i’s are dotted and t’s crossed but if the E/R gets too paranoid about the ORB it’s possible they can take their eye off the ball.