Gard reports that from 1 January 2026, the use or storage of fire-extinguishing media containing Perfluorooctane sulfonic acid (PFOS) will be prohibited under the Convention on the Safety of Life at Sea (SOLAS) and the High-Speed Craft (HSC) Codes — a significant development for maritime safety, environmental compliance and shipboard risk management.
PFOS, a persistent organic pollutant (POP) from the broader class of Per‑ and poly‑fluoroalkyl substances (PFAS), was once widely used in aqueous film-forming foams (AFFF) for extinguishing class B fires (flammable liquids) due to its excellent oil- and water-repellency. However, its same chemical stability means it does not break down easily in the environment, accumulates in living organisms and carries health risks such as liver damage, cardiovascular disease and infertility.
Why This Matters for Ships, Fleets and On-Board Systems
• The regulation affects both new and existing vessels: new builds (delivered on or after 1 January 2026) must comply immediately; existing ships must comply no later than their first survey after 1 January 2026.
• All fire-fighting systems must be scrutinised: shipowners and operators should review inventories and certificates now to identify any equipment containing PFOS-based media.
• Older installations may lack documentation: for extinguishing media installed prior to 2026 with incomplete records, sampling and testing may be required.
• Removal or replacement of non-compliant media is essential: PFOS-based foams should be removed, systems cleaned, and residues handled via approved reception facilities ashore.
• Verify new media compliance: replacement foams must be type-approved and certified under applicable IMO or regional guidelines.
• Secure audit evidence: manufacturer declarations or laboratory test reports must include type, production period, batch number and reference to type approval or MED certificate.
• Flag state certification remains key: the vessel’s flag administration or its Recognised Organisation (RO) must verify compliance during inspection or survey.
Impacts and Operational Considerations
The prohibition of PFOS in fire-fighting foams intersects with three major aspects of maritime operations: maritime safety, regulatory compliance and environmental stewardship.
- Maritime safety: Fire-fighting foams are crucial in controlling liquid fuel fires and protecting life and assets; the shift away from PFOS demands attention to alternative media performance and system readiness.
- Shipping technology: Foams and suppression systems are part of shipboard fire-protection technology; any replacement or retrofit must meet performance criteria and integrate seamlessly with existing systems.
- Environmental regulation: PFOS and other PFAS are subject to intensified global regulation — shipping professionals must ensure that onboard media and waste streams comply with SOLAS, SRR (Ship Recycling Regulation) and other frameworks.
Practical 5-Point Checklist to Get Ready Now
- Inventory all fixed and portable fire-fighting media and determine if PFOS-based foam is present.
- For installations where documentation is missing, arrange for sampling or lab testing to verify PFOS concentration (limit: 10 mg/kg or 0.001 % by weight).
- Replace or remove all non-compliant foam and purge systems thoroughly; ensure disposal via approved reception facilities.
- Obtain robust supplier declarations or test certificates to confirm that replacement foam is PFOS-free and type-approved.
- Present full compliance documentation to the flag administration or RO at the first survey post-January 2026.
While many vessels may currently be unaffected due to previous equipment upgrades or scrappage, the regulation still represents a material compliance requirement with financial, operational and reputational implications. Addressing this early ensures uninterrupted fleet operations, aligns with environmental goals and supports long-term safe shipping practices.
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Source: Gard
