Author: Daniel G. Teleoaca – Maritime Chief Engineer
The International Maritime Organization (IMO) has implemented significant amendments to SOLAS Chapter II-2 and the High-Speed Craft (HSC) Codes (1994 & 2000) to prohibit the use and storage of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS), including firefighting foams, on ships. This landmark regulation aims to enhance safety at sea and protect both human health and the marine environment. The ban becomes effective on 1 January 2026, impacting both new and existing vessels under SOLAS and HSC Codes.
Background: Why is PFOS Banned?
PFOS is part of a broader class known as “forever chemicals”—persistent organic pollutants that are highly resistant to environmental degradation. They can accumulate in human and animal tissue, posing risks to health and ecological systems. Traditionally, PFOS-based foams were popular for their firefighting efficiency, especially against flammable liquid fires. However, their proven toxicity and persistence led to this global regulatory shift.
Key Amendments and Resolutions
- SOLAS Chapter II-2: [MSC.532(107)]
- 1994 HSC Code: [MSC.536(107)]
- 2000 HSC Code: [MSC.537(107)]
These new requirements arise from the following IMO resolutions:
Supportive clarifications and unified interpretations:
- IACS Unified Interpretation SC309 (for SOLAS Regulation II-2/10.11)
- IACS Unified Interpretation HSC11 (for Regulation 7.9.4 of HSC Codes)
- IMO MSC.1/Circ.1694 (Unified interpretation of above regulations)
Scope and Application
Who Must Comply?
| Ship Construction Date | Compliance Requirement |
|---|---|
| Keel laid on or after 1 Jan 2026 | No use or storage of PFOS fire-extinguishing media >10mg/kg (0.001% by weight) at delivery |
| Keel laid before 1 Jan 2026 | Must comply no later than the first survey on or after 1 Jan 2026 |
- Applies to both fixed and portable firefighting systems and extinguishers.
- “First survey” refers to the first annual, periodical, or renewal survey after the effective date, or another as defined by Administration
Prohibited Substances Disposal
PFOS-containing extinguishing agents must be removed and disposed of in approved shore-based facilities
Documentation and Verification
Shipowners, managers, and operators must:
Obtain and keep on board manufacturer’s declarations for all fire-extinguishing media, specifying:
- Type, production period, batch number, Type Approval/MED Certificate reference.
- Provide documentation to surveyors proving PFOS levels do not exceed 10mg/kg.
- If documentation is missing: Arrange onboard sampling and testing according to recognized standards (e.g., NPR-CEN/TS 15968) to verify PFOS concentration.
What to Do Now: Step-by-Step
- Inventory audit: Review all firefighting foams and agents onboard for PFOS content.
- Documentation: Compile, verify, or acquire necessary compliance declarations and certificates.
- Testing: For legacy agents without valid documentation, plan testing in accordance with relevant standards.
- Replacement planning: Identify and source IMO-approved, PFOS-free alternatives ahead of the deadline.
- Plan for safe disposal: Coordinate with port reception facilities to remove and dispose of banned agents responsibly.
- Update hazardous materials inventory post-removal and ensure the vessel’s records are up to date.
The Future: Further PFAS Restrictions?
It is anticipated that IMO, the EU, and other regulatory authorities may expand prohibitions to chemicals within the wider PFAS family—such as perfluorooctanoic acid (PFOA) and others—in the years ahead. Vigilance and forward planning are advised for new investments in firefighting systems.
In conclusion, the IMO’s PFOS prohibition marks a decisive move toward safer, cleaner shipping. For all involved—shipowners, managers, engineers—the message is clear: Act now to audit, document, and replace PFOS-containing firefighting media before the 2026 cut-off. Through compliance, responsible leadership, and smart communication, the maritime community can help build a safer ocean for all
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