Maritime safety regulations are entering a new phase, with environmental and human health considerations now driving decisive policy changes. One such measure is the forthcoming ban on fire-extinguishing media containing PFOS (Perfluorooctane Sulfonic Acid). Adopted by the International Maritime Organization’s (IMO) Maritime Safety Committee (MSC) at its 107th session, the regulation will take effect on January 1, 2026.
For shipowners, the implications are significant. The ban affects both new and existing ships worldwide, with non-compliance likely to trigger costly disruptions and potential detentions. Importantly, the regulation also intersects with another familiar compliance framework: the Inventory of Hazardous Materials (IHM) under the EU Ship Recycling Regulation (EU SRR).
What Is PFOS and Why Is It Banned?
PFOS is a synthetic compound that has long been prized for its effectiveness in aqueous film-forming foams (AFFF), widely used to combat hydrocarbon fires at sea. Yet its environmental and health risks are profound:
- Persistence: PFOS does not degrade naturally and can remain in ecosystems for decades.
- Bioaccumulation: It accumulates in living organisms, including humans.
- Health Impacts: Studies link PFOS to liver damage, immune suppression, thyroid disruption, and possible carcinogenic effects.
The Stockholm Convention on Persistent Organic Pollutants (POPs) already restricts PFOS use, and IMO’s action eliminates its role in maritime firefighting systems.
The SOLAS Amendments
The regulatory basis for the ban is embedded in a series of amendments adopted on June 8, 2023:
- Resolution MSC.532(107) – Amendments to SOLAS Chapter II-2.
- Resolution MSC.536(107) – Amendments to the 1994 HSC Code.
- Resolution MSC.537(107) – Amendments to the 2000 HSC Code.
From January 1, 2026:
- Firefighting media containing more than 10 mg/kg of PFOS (0.001% by weight) will be prohibited.
- New ships (keel laid on or after January 1, 2026) must comply at delivery.
- Existing ships must comply no later than their first survey (annual, intermediate, or renewal) after the effective date. This 10 mg/kg limit effectively defines “PFOS-free” under IMO’s unified interpretations.
The IHM Connection
For vessels trading to or within Europe, the PFOS ban is inseparable from the EU SRR. PFOS is listed in Annex I of the EU SRR, requiring its inclusion in IHM Part I.
- EU-flagged ships and non-EU ships calling at EU ports must document PFOS presence or absence.
- While portable extinguishers are typically recorded under IHM Part III (stores), the ban extends compliance to both fixed and portable systems.
As a result, owners must address PFOS risks in tandem with their IHM obligations, ensuring updated documentation and Class-approved Statements of Compliance.
What Shipowners Must Do
Shipowners face a multi-step compliance process:
1. Identify At-Risk Equipment
- Fixed deck foam systems on tankers, FPSOs, and offshore vessels.
- Engine room foam systems.
- High-expansion foam systems in cargo holds.
- Portable extinguishers using AFFF, FP, or AR-AFFF foams.
2. Gather Documentation
- Obtain a Manufacturer’s Declaration confirming PFOS-free status.
- If unavailable, send samples to an ISO 17025-accredited laboratory.
3. Test and Record
- Confirm PFOS content ≤ 10 mg/kg.
- Update records and IHM accordingly.
4. Replace and Dispose
- Replace foams exceeding the threshold with PFOS-free alternatives.
- Dispose of PFOS-containing foams through licensed hazardous waste facilities.
5. Maintain Certificates
- MED or Type Approval Certificates for replacement foams.
- Maker’s Declarations or lab results.
- Updated IHM and compliance statements.
The Cost of Compliance
For many vessels, existing PFOS foams remain in storage tanks, drums, or portable units, often with incomplete documentation. Compliance costs may include:
- Laboratory sampling and testing.
- Replacing entire foam inventories.
- Cleaning and flushing firefighting systems.
- Licensed disposal of hazardous waste.
- Documentation updates and IHM revisions.
Estimates suggest the expense can reach hundreds of thousands of dollars per vessel, magnified exponentially for fleet operators.
Conclusion
The PFOS ban under SOLAS, effective January 1, 2026, represents more than a regulatory update—it is a major environmental and safety milestone for the maritime industry. By aligning with EU IHM requirements, the regulation underscores the need for early, coordinated action.
Shipowners who delay risk not only steep compliance costs but also operational disruption when surveyors demand proof of PFOS-free firefighting systems. As with ballast water treatment and low-sulphur fuel mandates, preparation will determine whether this transition is smooth or financially painful.
The message is clear: start identifying, documenting, and replacing PFOS-containing foams now. Proactive compliance is the only safeguard against costly surprises when the 2026 deadline arrives