FAQ IHM Maintenance

Each Classification Society has different requirements pertaining to this. In our experience, most of them require the suppliers to follow the declaration form formats as per EU SRR and Class regulations/guidelines, and provide part specific declarations

Each Classification Society has different requirements pertaining to this. In our experience, most of them require the suppliers to follow the declaration form formats as per EU SRR and Class regulations/guidelines, and provide part specific declarations.

MSDS are not required if declaration forms have already been submitted, however if you require assistance in declaring of the HM material mass, then the MSDS may be used for verification purposes.

The forms are also available in dual languages in Chinese/Korean/Japanese versions. Please note the information input must be in English in accordance with the regulations/guidelines.

Yes, digital signatures are acceptable.

Yes, Metizoft can provide a reference copy of the declaration forms but with the confidential details blanked out.

Yes, Metizoft can assist to check but please note the ultimate responsibility of the correctness of the forms lies with the declarer.

The declarations consist of the Material Declaration (MD) and Supplier Declaration of Conformity (SDoC) forms. As stipulated by the regulations/guidelines, each unique goods/component/equipment needs to have an individual MD form.

You will be required to submit the declaration(s) each time the goods are supplied onboard the vessel. However if you are able to indicate the unique part no and/or description in the first declaration, we will record the information in our system and if the same part is supplied again for the vessel, we will not ask for the declaration from you again.

As of now, Metizoft only has the PO number from the ship owner/manager, if you require the supplier reference number, we will check with the ship owner/manager.

If the part numbers are available in the ship owner/manager's PO, Metizoft can request the information from them; otherwise as the supplier or manufacturer, you should be able to get this information from your principal or factory.

According to the PO information from the ship owner/manager, your company is the direct seller of the goods to them. Please try to locate the order again, Metizoft will consult with the ship owner/manager's purchaser if you are still unable to do so.

Please refer to "Guideline to fill in MD and SDoC" for reference.

In accordance with Section 3 of the Resolution MEPC 269(68), it is the supplier in the first tier who is responsible for providing IHM documentation. You may request from your sub suppliers (tier 2 and onwards suppliers) for the relevant information if you cannot develop the MD based on the information available.

MD and SDoC form submissions are required by IMO MEPC 269(68) regulations/guidelines. For ship owners/managers, non compliance may lead to failure of the vessel to comply with EU SRR regulations/guidelines and consequently penalties imposed on the vessel by the Port State Control. For suppliers, non compliance may result in the ship owners/managers ceasing to purchase from you in the future, as the entire supply chain needs to comply to this regulation.

Metizoft is not the supplier and is acting on behalf of the ship owner/managers for compilation of the IHM documentations to comply with the regulations/guidelines. The responsibility of the IHM declarations lies with the components/parts/equipment suppliers. Metizoft can assist you to fill in the declaration forms, but the contents have to be input and verified by you; note the declarations are legal binding document which requires your signatures.

The agreement is usually stated in the PO or contract between you and the ship owner/manager. If required Metizoft can communicate with the ship owner/manager including you in the loop to clarify.

There could be a few possible scenarios for the difference in requirements:

1. The other vessel is not EU flagged or not calling at EU ports/anchorages
2. The other vessel's Class notation does not require IHM
3. The other vessel does not have prior IHM maintenance contract
4. The other vessel could have identical parts with prior declarations

If declaration for the scope of supply is required under the regulations/guidelines, then monetary value is not applicable and declaration for all items are required to comply with the regulations/guidelines.

Tier 1 suppliers can based on written communication from sub-suppliers as evidence to sign off the declarations.

Metizoft suggests you keep the necessary documentation trail for audit purposes should the situation really arise. If necessary, you can also send the equipment/part/component for lab testing.

Yes, in that case the person shall be acting on your behalf and you shall bear full responsibility for his/her outputs, and as the tier-1 supplier.

Metizoft suggests you send the request to alternative manufactuers/distributors of the same product (e.g. in other countries).

Metizoft is acting on behalf on the ship-owner in requesting the declarations from you and is unable to comment as the commercial contract is between the ship-owner and suppliers, suggest you to approach the ship owner/manager for this matter.

The manufacturer will have the information of the constituent material of the component/equipment/part, and some of them will publish this information in a Material Data Sheet (MDS) or Safety Data Sheet (SDS). Verification using such information can be done before filling in and signing of the forms.

As Metizoft is not the manufacturer of the equipment/system and has no means to verify whether it is a standard part, and Metizoft is only provided with the information of the part/component as informed by the ship owner/manager, hence if the submitted declaration does not match the purchase information from the ship owner/manager, the supplier will be requested to change the description to that of the part/component.

In accordance with IMO MEPC 269(68) regulation/guideline, the responsibility of data collection for HM declaration lies with the Tier-1 supplier. If you are not the original manufacturer of the parts, you are required to verify with your principals/factories and submit the declarations as the Tier-1 supplier. The signed declaration forms are required by the approving Classification Society for review and approval, and you may use the MSDS from your principals/factories for verification.

IHM is primarily based on the following regulations/guidelines:

1. Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 [HKC] using IMO MEPC.379(80) as reference

2. Regulation (EU) No. 1257/2013 [EU SRR] using EMSA Guidance on the Inventory of Hazardous Materials as reference

In accordance with the regulations/guidlines, declarations are required for all equipment/system/component/part associated with the vessel's paint, hull, structure and equipment/systems onboard. As an IHM expert company, Metizoft will assist you accordingly.

In accordance with the regulations/guidelines, the following are exempted:

1. Materials listed in Table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.

2. Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.

The following are sources of information on IHM.

1. IMO MEPC 269(68) guidelines

2. EMSA Guidance on the Inventory of Hazardous Materials

3. Metizoft websites

4. Respective Classification Societies' guidelines (refer to their websites for information and reference)

Please note that the EU SRR regulation is already in force (since Dec 2013) and applies to all EU flagged vessels and 3rd party flagged vessels calling on EU ports and anchorages.

Dangerous Goods are not the same as Hazardous Materials.

As the vessels are required to attain the relevant IHM notation from the approving Classification Society, all equipment/parts/material suppliers to the vessels have to fill in and endorse on the declaration forms to facilitate Class review and approval. If you are not the original manufacturer of the parts, you are required to verify with your principals/factories and submit the declarations as the Tier-1 supplier.

Type testing and certification are not applicable for HazMat which is not a product compliance feature. There are a few options to check for HazMat:

1. Material Safety Data Sheet (MSDS)

2. Bill of Material (BOM)

3. Equivalent certification, for example Restriction of Hazardous Substances Directive (RoHS)

ISO and IHM are separate subject matters. ISO accreditation is related to aspects of quality of the manufacturing process.

RoHS does not cover all the 15 hazardous substances listed in the IHM regulations/guidelines. You may use RoHS as reference for the applicable Table B substances; for Table A substances, separate verification is required.