If Part I of your Inventory of Hazardous Materials is the what, then Material Declarations and Supplier’s Declarations of Conformity are the proof. They are the documents that turn “we think this component is asbestos-free” into a defensible record a surveyor can rely on. They are also, on most yachts, the single most scattered, hardest-to-find category of paperwork on board.
This is a guide to getting that paper trail under control — what these documents are, when you need one, and how to keep them attached to the inventory entries they support.
What MD and SDoC actually are
Two documents, working as a pair:
- Material Declaration (MD) — a structured statement from a supplier or manufacturer declaring whether a product contains materials from the IHM’s controlled-substance list, and if so, where and in what quantity. It is keyed to the substance tables the IHM Guidelines (IMO resolution MEPC.379(80)) define.
- Supplier’s Declaration of Conformity (SDoC) — the supplier’s signed statement that the accompanying MD is accurate and that the product conforms to it.
Together they are the evidence chain behind a Part I entry. When a surveyor asks “how do you know this equipment is compliant?”, the MD/SDoC is the answer.
When you need one
You need an MD/SDoC whenever a controlled material is introduced, removed, or changed in the vessel’s structure or equipment. In practice, that means:
- At a refit — any time equipment is installed, replaced, or modified. This is the big one, and the moment it is easiest to collect the paperwork, because the contractor is right there. (Our refit briefing for DPs and Chief Engineers goes deep on this.)
- At equipment replacement — a new pump, a new switchboard, a new insulation run.
- At new-build and major conversion — where the full MD/SDoC set is assembled from the yard and its suppliers.
A like-for-like replacement of a component with no controlled materials does not need an entry — but you still want the declaration on file that says so.
The golden rule: collect it at the source
The hardest MD/SDoC to obtain is the one you go looking for six months after the yard has been paid and moved on. The easiest is the one you ask for as a condition of the work.
The discipline that saves yachts most pain is simple: make MD/SDoC a deliverable of the job, not an afterthought. Build it into the contractor’s scope — the work is not “done” until the declaration is in hand. This single habit prevents most of the gaps that later show up as Port State Control findings (see what the inspector actually checks).
The problem: documents that scatter
Here is the failure mode almost every yacht knows. The MDs arrive — a PDF in an email from the yard, a scan from a supplier, a paper copy in a folder somewhere. Part I gets updated (sometimes). And then the connection between the inventory entry and the document that proves it quietly dissolves. A year later, the entry exists but no one can find the declaration behind it.
The records and the evidence drift apart. At survey, that drift is exactly what costs time.
The fix: keep the document with the change
The structural fix is to stop treating the inventory and its evidence as two separate filing systems. Every Part I change has a document that supports it; the two should live together, so that opening the entry shows the declaration, and opening the declaration shows what it changed.
That is the model MANTIS is built around. When a material changes, you log the change against Part I and attach the MD/SDoC to it in the same step. The documentation chain is assembled as you go — not reconstructed from email the week before a survey. When it is time to compose a survey pack, the supporting documents are already where they belong.
It is the difference between a paper trail you maintain and a paper trail you excavate.
In short
- MD and SDoC are the evidence behind Part I — keyed to the controlled-substance tables in MEPC.379(80).
- You need them whenever a controlled material changes — most often at a refit.
- Collect them at the source, as a deliverable of the work, never after the fact.
- Keep each document attached to the inventory change it supports, so the chain stays intact for the survey.
For the full picture of how Part I, the supporting documentation, and the survey cycle fit together, see our complete guide to IHM for superyachts.
MANTIS is IHM compliance management software for superyachts. It stores MD/SDoC documentation against the Part I change it supports, tracks certificate expiry and survey intervals, and generates survey-pack PDFs for class society review. Start free beta →