PFOS Ban In Firefighting Media – A Critical Regulation Shipowners Cannot Ignore

Maritime safety regulations continue to evolve, often driven by environmental and human health concerns. One such pressing issue is the upcoming ban on PFOS-containing fire-extinguishing media under the International Maritime Organisation (IMO). This new regulation, adopted by the Maritime Safety Committee (MSC) at its 107th session, is set to enter into force on 1 January 2026.

The impact will be felt across the global fleet, and shipowners must act now to avoid operational disruptions and costly last-minute replacements. Beyond safety, the regulation is also tightly connected with another compliance framework familiar to many owners: the Inventory of Hazardous Materials (IHM) under the EU Ship Recycling Regulation (EU SRR).

What is PFOS, and Why is It Banned?

PFOS (Perfluorooctane Sulfonic Acid) is a synthetic chemical widely used in AFFF firefighting foams for its ability to spread rapidly and suppress hydrocarbon fires. Unfortunately, PFOS is also a persistent organic pollutant (POP):

• It does not degrade naturally and can persist in the environment for decades.
• It bioaccumulates in living organisms, including fish and humans.
• It is linked to liver damage, immune suppression, thyroid disruption, and possible carcinogenic effects.

The Stockholm Convention on POPs has already listed PFOS as a restricted substance, and IMO has now acted to eliminate its use on ships.

The SOLAS Amendment and MSC Circulars

The regulatory foundation comes from:

• Resolution MSC.532(107) – Amendments to SOLAS Chapter II-2 (fire protection, detection and extinction).
• Resolution MSC.536(107) – Amendments to the 1994 HSC Code.
• Resolution MSC.537(107) – Amendments to the 2000 HSC Code.

These were adopted on 8 June 2023 and will enter into force on 1 January 2026.

Key Requirement

From this date, ships must not use or store fire-extinguishing media containing PFOS above 10 mg/kg (0.001% by weight). This threshold is considered the “PFOS-free” definition under IMO’s unified interpretations.

• New ships (keel laid on or after 1 January 2026): Must comply upon delivery.
• Existing ships: Must comply no later than their first survey (annual, intermediate, or renewal) after 1 January 2026.

The IHM Connection – Why It Matters

For shipowners trading to Europe, the EU Ship Recycling Regulation (EU SRR) adds another layer of compliance. PFOS is specifically listed in Annex I of the EU SRR as a hazardous material that must be included in IHM Part I.

• EU-flagged ships and non-EU ships calling at EU ports must document the presence (or absence) of PFOS in their IHM.
• Portable fire extinguishers are recorded in IHM Part III (stores), but under the PFOS ban, both fixed systems and portable extinguishers must be checked and documented.

This means the PFOS regulation and IHM obligations are interlinked: compliance with one supports the other, but both must be addressed separately.

What Must Shipowners Do?

1. Identify Equipment at Risk

PFOS may be present in:

• Fixed deck foam systems (tankers, FPSOs, offshore vessels).
• Engine room foam systems.
• High-expansion foam systems in cargo holds.
• Portable foam extinguishers (AFFF, FP, AR-AFFF types).

2. Gather Documentation

• Obtain a Manufacturer’s Declaration (MD) confirming PFOS-free status.
• If not available, collect samples of foam concentrate or chemical agent and send to an ISO 17025-accredited laboratory for PFOS analysis.

3. Test and Record

• Confirm PFOS content is ≤ 10 mg/kg.
• Record results in ship documentation and update the IHM accordingly.

4. Replace and Dispose

If PFOS is detected above limits:

• • Replace foam with PFOS-free alternatives (typically AFFF 3% or 6%, AR-AFFF, or fluorine-free foams, depending on system design).
  • Dispose of old foam via licensed hazardous waste facilities 

5. Maintain Certificates

Keep the following readily available for surveyors:

• • MED or Type Approval Certificates of replacement foam.
  • Maker’s Declarations or laboratory test results.
  • Updated IHM documents and Class-approved Statement of Compliance.

EU Flag vs. Non-EU Flag Vessels

Why This Regulation Can Be Costly?

For many ships, PFOS foams may still be in storage tanks, drums, or portable extinguishers without clear documentation. The cost of:

• Sampling and testing,
• Replacing entire foam inventories,
• Cleaning/flushing systems,
• Hazardous waste disposal,
• Updating IHM and documentation,

…can run into hundreds of thousands of dollars per vessel. For fleets, this becomes a major compliance expense if not planned in advance.

Conclusion

The ban on PFOS-containing firefighting foams under SOLAS from 1 January 2026 is more than a regulatory detail — it is a critical safety and environmental obligation. With direct links to the EU IHM requirements, shipowners and managers must begin preparations now: checking declarations, sampling foams, arranging replacements, and updating inventories.

Failure to comply will not only expose ships to detentions and penalties but also create last-minute operational disruptions when surveyors demand evidence at renewal.

Like ballast water treatment or low-sulphur fuel regulations before it, the PFOS ban is another critical compliance milestone that may turn into a costly affair for unprepared shipowners. The message is clear: start the checks now, document your compliance, and avoid a rush against the 2026 deadline.

You might also like to read-

• Safety of Life at Sea (SOLAS) – The Ultimate Guide
• Watertight Doors on Ships: Types, Drills, Maintenance & SOLAS Regulations
• What is International Maritime Organization (IMO)?
• 5 Instruments of International Maritime Organization (IMO) Every Seafarer Should Know

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About Author

Marine Mechanics is a subsidiary of the Synergy Marine Group. Established in 2014, it is a premier service provider in the fields of Navigation, Communication, Automation, IT, LSA/FFA, and IHM. Their team comprises over 100 highly skilled engineers who successfully address more than 1,000 service calls each year.