- New SOLAS and HSC Code Amendments Target PFOS Firefighting Media.
- Shipowners Urged to Replace PFOS Foams Ahead of 2026 Deadline.
- Gard Issues Guidance on IMO’s PFOS Compliance Requirements.
Starting January 1, 2026, ships will no longer be allowed to use or store fire-extinguishing media that contains perfluorooctane sulfonic acid (PFOS), often referred to as a ‘forever chemical.’ This ban is part of updates to the International Maritime Organisation’s (IMO) Safety of Life at Sea (SOLAS) Convention and the High-Speed Craft (HSC) Codes, as outlined in loss-prevention guidance from P&I club Gard, reports Lloyd’s List.
Why PFOS Was So Popular
PFOS has been a go-to choice for many years due to its exceptional resistance to heat and its ability to repel both oil and water, making it particularly effective in tackling Class B fires that involve flammable liquids. It found its way into various industries, especially in firefighting foams used on ships and at shore facilities.
Environmental and Health Risks
One of the major issues with PFOS is its persistence in the environment; it contaminates soil, groundwater, and food chains. It builds up in living organisms and has been associated with serious health problems like cancer, liver damage, cardiovascular issues, and infertility. Due to these dangers, PFOS was designated as a Persistent Organic Pollutant (POP) under the 2009 Stockholm Convention, prompting many land-based fire departments to discontinue its use years ago.
IMO Implements Global Compliance Standards
The IMO is now taking steps to phase out PFOS from shipboard applications through amendments to SOLAS Chapter II-2 and the 1994 and 2000 HSC Codes. These new regulations will affect both fixed and portable firefighting systems, capping the allowable PFOS concentration at 10 mg per kg (0.001% by weight).
- Any new vessels constructed on or after January 1, 2026, will need to meet these standards upon delivery.
- Existing vessels must adhere to these regulations by their first survey after January 1, 2026.
Steps for Shipowners to Ensure Compliance
Gard suggests that shipowners implement a well-organised compliance plan that includes the following steps:
- Review system inventories and safety certificates to pinpoint any systems containing PFOS.
- If documentation is missing, carry out sampling and laboratory testing.
- Remove or replace any non-compliant firefighting media and ensure they are sent to approved shore-based reception facilities.
- Thoroughly clean tanks and systems to eliminate any PFOS residues.
Requirements for Replacement Equipment
When it comes to replacement firefighting media, all items must be type-approved and certified according to the relevant IMO guidelines. The necessary documentation should consist of:
- A declaration from the manufacturer
- Laboratory test reports
- Information such as product type, production period, batch number, and a reference to the type approval certificate
Simply stating that foam is PFOS-free won’t cut it; compliance needs to be confirmed by the flag state or a recognised organisation.
Updating Inventory of Hazardous Materials (IHM)
If PFOS is detected, ships are required to update their Inventory of Hazardous Materials (IHM) in line with both EU and IMO regulations for the Hong Kong Convention. Gard mentioned that classification societies can provide valuable assistance to shipowners who encounter difficulties during this process.
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Source: Lloyd’s List
