IMO Bans PFOS in Firefighting Media from 2026

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  • SOLAS and HSC Code Amendments Prohibit PFOS Use.
  • New Rules Apply to All Ships from 1 January 2026.
  • Disposal of PFOS Media Must Use Approved Facilities.

The International Maritime Organisation (IMO) has made some important updates to SOLAS Chapter II-2 and the HSC Codes from 1994 and 2000. Starting January 1, 2026, fire-extinguishing media that contain perfluorooctane sulfonic acid (PFOS) will be banned. This rule applies to both fixed and portable systems, reports LR.

Adopted resolutions

  1. SOLAS: MSC.532(107)
  2. 1994 HSC Code: MSC.536(107)
  3. 2000 HSC Code: MSC.537(107)

Supporting clarifications include:

  1. IACS SC309 (SOLAS II-2/10.11)
  2. IACS HSC11 (HSC 7.9.4)
  3. IMO MSC.1/Circ.1694: Unified interpretations of SOLAS and HSC Codes

Requirements by Ship Construction Date

  1. For ships constructed on or after January 1, 2026, they must not use or store any PFOS-containing media that exceeds 10 mg/kg (0.001% by weight) at the time of delivery.
  2. For ships built before January 1, 2026, they need to comply with their first survey on or after January 1, 2026.

Disposal and Compliance

  1. Disposal should be done using approved shore-based facilities.
  2. Manufacturers must provide a declaration that includes the media type, batch number, and type approval, which should be available on board.
  3. If there’s no declaration or test report, sampling and testing must follow a recognised standard (like NPR-CEN/TS 15968).

Shipowner Actions Before First Survey

By the first survey on or after January 1, 2026, shipowners should ensure:

  1. Proof that PFOS-free media has been used or that proper disposal has taken place.
  2. Replacement media that has type approval.
  3. An updated inventory of hazardous materials.

According to MSC.1/Circ.1290, The First Survey refers to the first annual, periodic, or renewal survey after the regulation date, or any other suitable survey as determined by the Administration. Looking ahead, there may be more restrictions on other PFAS chemicals, like PFOA, from the IMO, EU, and other organisations.

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Source: LR