Implement a proactive compliance plan to identify, remove and replace PFOS-containing fire-extinguishing media before the 1 January 2026 prohibition,
From 1 January 2026, the use or storage of fire-extinguishing media containing perfluoro octane sulfonic acid (PFOS) will be prohibited. New vessels, those constructed on or after 1 January 2026, must comply upon delivery. Existing vessels must comply no later than the first survey conducted on or after 1 January 2026, with the term “first survey” interpreted in accordance with MSC.1/Circ.1290.
PFOS, a persistent and toxic member of the PFAS family once widely used in fire-fighting foams, poses serious environmental and health risks due to its persistence and bioaccumulation.
Be prepared
Vessel owners, operators, and masters should take note of the amended regulations and begin preparations now to ensure timely compliance. Each vessel should implement a structured compliance plan that includes the following actions:
- Review system inventories and safety certificates: Identify all fire-fighting systems and equipment that contain PFOS-based extinguishing media.
- Assess older installations: For extinguishing media installed before 1 January 2026 for which proper documentation is unavailable, conduct sampling and testing of the media onboard in accordance with a recognized standard.
- Remove or replace non-compliant media: Non-compliant extinguishing media should be removed or replaced. Thoroughly clean PFOS residues from tanks and systems, and deliver all PFOS-based media removed from the vessel to appropriate shore-based reception facilities.
- Verify new media compliance: Ensure all replacement extinguishing media are suitably type-approved and certified in accordance with applicable IMO guidelines.
- Secure evidence: Collect documentation – such as a manufacturer’s declaration or laboratory test report – confirming that all extinguishing media onboard are PFOS-free. Note that a simple statement from the manufacturer claiming the foam is PFOS-free may not be sufficient. A proper declaration should include details such as type, production period, batch number, and reference to the type approval/MED certificate for the media.
- Confirm compliance with the flag administration: Compliance with the PFOS prohibition must be verified by the vessel’s flag administration or its recognized organization (RO). This can be achieved either by presenting the required manufacturer’s declarations or laboratory test reports to the attending surveyor during onboard inspections, or – if any changes or replacements of extinguishing media have been made – by submitting the relevant documentation for approval.
Note that PFOS may be recorded in a ship’s Inventory of Hazardous Materials (IHM) Part I, in accordance with the EU Ship Recycling Regulation (EU SRR), which implements the Hong Kong Convention (HKC). Any removal of PFOS-containing materials must be reflected in an updated IHM, ensuring compliance with both EU and IMO requirements.