Ban on PFOS in Firefighting Agents

Ban on Perfluorooctane Sulfonate (PFOS) in Firefighting Agents – A Critical Regulation Shipowners Must Not Ignore

Maritime safety regulations are constantly evolving, often driven by concerns about the environment and human health. One pressing issue is the International Maritime Organization (IMO)’s upcoming ban on firefighting agents containing perfluorooctane sulfonate (PFOS). This new regulation, adopted by the 107th session of the Maritime Safety Committee (MSC), is expected to take effect on January 1, 2026.

The global fleet will be affected, and shipowners must take immediate action to avoid operational disruptions and costly emergency replacements. Beyond safety, this regulation is closely tied to another compliance framework familiar to many shipowners: the Inventory of Hazardous Materials (IHM) under the EU Ship Recycling Regulation (EU SRR).

What is Perfluorooctane Sulfonate (PFOS)? Why is it banned?

PFOS (perfluorooctane sulfonate) is a synthetic chemical widely used in aqueous film-forming foam (AFFF) firefighting foams due to its ability to spread rapidly and suppress hydrocarbon fires. However, PFOS is also a persistent organic pollutant (POP):

• It does not degrade naturally and can persist in the environment for decades.
• It accumulates in organisms, including fish and humans.
• It can cause liver damage, immunosuppression, thyroid dysfunction, and may be carcinogenic.

The Stockholm Convention on Persistent Organic Pollutants has listed PFOS as a restricted substance, and the International Maritime Organization (IMO) has taken action to ban its use on ships.

Amendments to the International Convention for the Safety of Life at Sea and MSC Circulars

Regulatory authorities are as follows:

Resolution MSC.532(107) – Amendments to Chapter II-2 (Fire Prevention, Detection and Extinguishing) of the International Convention for the Safety of Life at Sea.

Resolution MSC.536(107) – Amendments to the 1994 IMO Code.

Resolution MSC.537(107) – Amendments to the 2000 Code of Safety of Hazardous Chemicals. The amendment was adopted on June 8, 2023, and will take effect on January 1, 2026.

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Key Requirements

From that date, ships must not use or store fire extinguishing agents containing more than 10 mg/kg (0.001% by weight) of PFOS. This threshold is considered “PFOS-free” under the International Maritime Organization’s unified interpretation.

New ships (ships whose keels are laid on or after January 1, 2026): Compliance is required upon delivery.

Existing ships: Compliance is required before the first survey (annual, intermediate, or renewal) after January 1, 2026.

IHM Connection – Why It Matters

For shipowners sailing to and from Europe, the EU Ship Recycling Regulation (EU SRR) adds another layer of compliance. Annex I to the EU SRR specifically lists perfluorooctane sulfonic acid (PFOS) as a hazardous substance, requiring inclusion in Part I of the International Health Manual (IHM).

EU-flagged ships and non-EU ships calling at EU ports must record the presence (or absence) of PFOS in their International Health Manual (IHM).

Portable fire extinguishers are recorded in Part III (Storage Facilities) of the IHM, but under the PFOS ban, both fixed fire-fighting systems and portable fire extinguishers must be inspected and recorded.

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

What must shipowners do?

PFOS may be present in:

• Fixed deck foam systems (tankers, floating production storage and offloading vessels (FPSOs), and offshore vessels).
• Engine room foam systems.
• High-expansion foam systems in cargo holds.
• Portable foam extinguishers (water-based foam (AFFF), floating production storage and offloading (FPSO), and aerated water-based foam (AR-AFFF) types). Collect Documents
• Obtain a Manufacturer’s Declaration (MD) confirming the absence of PFOS.
• If this is unavailable, collect a sample of the foam concentrate or chemical formulation and send it to an ISO 17025-accredited laboratory for PFOS analysis.
• Testing and Recordkeeping
• Confirm that the PFOS content is ≤ 10 mg/kg.
• Record the results in the vessel’s documentation and update the IHM accordingly.

Replacement and Disposal

If an excessive PFOS level is detected:

• Replace the foam with a PFOS-free alternative (typically 3% or 6% aqueous film-forming foam (AFFF), AR-AFFF, or fluorine-free foam, depending on the system design).
• Dispose of the old foam through a licensed hazardous waste disposal facility.
• Retain Certificates

Keep the following documents readily available to the surveyor:

• MED or type approval certificate for the replacement foam.
• Manufacturer’s Declaration or laboratory test results.
• Updated IHM and Declaration of Conformity approved by the classification society.
• EU-Flagged and Non-EU-Flagged Ships

Why is this regulation costly?

For many ships, PFOS foam may still be stored in tanks, drums, or portable fire extinguishers, with no clear record-keeping. The costs of:

• sampling and testing,
• replacing the entire foam inventory,
• cleaning/flushing the system,
• hazardous waste disposal,
• updating the IHM and documentation,
• can reach hundreds of thousands of dollars per ship. For fleets, this can become a significant compliance expense without advance planning.

Conclusion

The ban on the use of PFOS-containing firefighting foams under the International Convention for the Safety of Life at Sea (SOLAS) from January 1, 2026, is not just a regulatory detail; it is a crucial safety and environmental obligation. Directly linked to EU IHM requirements, shipowners and managers must begin preparations immediately: inspecting declarations, sampling foam, arranging replacements, and updating inventories.

Failure to comply not only results in vessel detention and penalties, but also in last-minute disruptions to vessel operations when inspectors request renewal certificates.

Like ballast water treatment regulations or low-sulfur fuel, the PFOS ban is another critical compliance milestone that could be costly for unprepared shipowners. The message is clear: start inspections now, document your compliance, and avoid rushing ahead of the 2026 deadline.