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A ticking clock for shipowners: by January 1, 2026, fire-fighting foams containing PFOS will be completely banned onboard all vessels—new and existing.



Introduction

The maritime industry is under growing pressure from global regulators to eliminate hazardous substances onboard vessels. One such substance, Perfluorooctane Sulfonic Acid (PFOS), long used in fire-fighting foams for its effectiveness against flammable liquid fires, has been classified as a Persistent Organic Pollutant (POP) due to its toxicity, bioaccumulation, and environmental persistence.

PFOS is already banned under the Stockholm Convention and restricted by regional frameworks such as the EU Regulation (2019/1021) on POPs. Despite these measures, PFOS-containing foams may still be found onboard older vessels—posing serious environmental, health, and compliance risks.

To address this, the International Maritime Organization (IMO) has adopted key amendments to the SOLAS Convention. From 1 January 2026, the use and storage of fire-fighting foams containing PFOS will be prohibited on all ships.

What is PFOS?

PFOS (Perfluorooctane Sulfonic Acid) belongs to the broader chemical family PFAS (Per- and Polyfluoroalkyl Substances), known for their strong resistance to heat, water, and oil.

PFOS has been widely used in:

  • Fire-fighting foams (AFFF)
  • Water- and stain-resistant textiles and carpets
  • Grease-proof coatings for food packaging
  • Industrial cleaning agents and insecticides

Its chemical stability makes it highly functional but also extremely persistent—it does not break down easily in the environment or in living organisms.

Why is PFOS Dangerous?

  • Bioaccumulation: PFOS builds up in the bodies of humans and wildlife.
  • Health risks: Linked to liver damage, immune suppression, developmental toxicity, and cancer.
  • Environmental persistence: PFOS can remain in soil and water for decades.

In fire-fighting foams, PFOS contamination spreads quickly through runoff into groundwater during training or emergencies—making its elimination critical.

New IMO and SOLAS Regulations – Effective 1 January 2026

The IMO has adopted amendments under Resolution MSC.532(107) and issued MSC.1/Circ.1694 to ensure compliance.

Key Regulatory Updates

  • SOLAS Chapter II-2, Regulation 10.11.2 – Prohibits the use and storage of PFOS-containing fire-extinguishing foams.
  • 1994 & 2000 HSC Codes, Regulation 7.9.4 – Extends the same prohibition to high-speed craft.

The IMO has amended SOLAS Chapter II-2 and the HSC Codes to prohibit the use and storage of fire-extinguishing media containing PFOS, including firefighting foams, in both fixed and portable systems and equipment. This regulation takes effect on January 1, 2026.

  1. Fixed Systems: Includes onboard fixed fire suppression systems like sprinklers and deluge systems.
  2. Portable Systems: Covers handheld extinguishers and portable foam applicators.
  3. Equipment: Applies to fire protection equipment such as foam proportioning units and extinguishing foam storage tanks.

Who Must Comply?

  • New Ships – All ships constructed on or after 1 January 2026 must comply at delivery.
  • Existing Ships – Ships built before 1 January 2026 must comply no later than the date of their first annual, intermediate, or renewal survey after 1 January 2026.

What Constitutes PFOS-Containing Foam?

  • Fire-fighting foam is considered PFOS-based if concentration exceeds 10 mg/kg (0.001% by weight).
  • Compliance verification:
    • Manufacturer's declaration
    • Type approval or certification
    • Laboratory testing reports
  • If documentation is unavailable, especially on older vessels, sampling and testing must be carried out in line with international standards.

Steps for Shipowners, Operators, and IHM Inspectors

1. Audit Onboard Fire-Fighting Systems

Check all fixed foam systems, portable extinguishers, and reserve foam stocks.

2. Remove and Dispose of PFOS Foams

PFOS-containing foams must be removed before 1 January 2026 and delivered to shore-based reception facilities. Record all removals in the ship's logbook.

3. Replace with Approved Alternatives

Install IMO-approved, PFOS-free foam concentrates:

  • High-expansion foams – MSC/Circ.670
  • Low-expansion foams – MSC.1/Circ.1312

Non-Compliance Risks

Failure to comply can result in:

  • Port State Control detention
  • Loss of statutory certification (e.g., Safety Equipment Certificate)
  • Operational delays during drydock or recycling
  • Environmental liability for contamination

How Varuna Sentinels BV Can Support

As a trusted IHM service provider, Varuna Sentinels BV offers:

  • PFOS detection surveys
  • Sampling & lab testing coordination
  • IHM maintenance and updating services
  • Environmentally sound disposal assistance

We help ensure your fleet is fully compliant ahead of deadlines, reducing risk and avoiding costly delays.

Final Thoughts

The 2026 PFOS ban is more than just a regulatory update—it is a major step toward safer ships, cleaner oceans, and sustainable shipping. Acting early will save costs, prevent operational disruption, and strengthen your commitment to environmental responsibility.

Need help updating your IHM or verifying PFOS compliance?

Reach out to Varuna Sentinels BV at contact@varuna-sentinels.com or visit our website www.varuna-sentinels.com

References

  1. Amendments to the International Convention for the Safety of Life At Sea, 1974 SOLAS Chapter II-2, Part C, Regulation 10 – Fire-Fighting (https://ww2.eagle.org/content/dam/eagle/regulatory-news/2024/msc-532-107.pdf)
  2. Amendments to the International Code of Safety for High-Speed Craft, 1994 High-Speed Craft Code (HSC) Chapter 7 Part A, Regulation 7.9 (https://ww2.eagle.org/content/dam/eagle/regulatory-news/2024/msc-536-107.pdf)
  3. Amendments to the International Code of Safety for High-Speed Craft, 2000 High-Speed Craft Code (HSC) Chapter 7 Part A, Regulation 7.9 (https://ww2.eagle.org/content/dam/eagle/regulatory-news/2024/msc-537-107.pdf)
  4. Report of the eleventh session of the Sub-Committee. (https://ww2.eagle.org/content/dam/eagle/regulatory/intrasite/05-07-2025/MSC%20110-14%20-%20Report%20of%20the%20eleventh%20session%20of%20the%20Sub-Committee%20(Secretariat)%20(1).pdf)
  5. Guidelines for The Performance and Testing Criteria and Surveys of High Expansion Foam Concentrates for Fixed Fire-Extinguishing Systems. (https://ww2.eagle.org/content/dam/eagle/regulatory/intrasite/05-07-2025/MSC-ci_670.pdf)
  6. Revised Guidelines for the Performance and Testing Criteria, and Surveys of Foam Concentrates for Fixed Fire-Extinguishing Systems (https://ww2.eagle.org/content/dam/eagle/regulatory/intrasite/05-07-2025/ABS-Offshore-Floating-Production-BRZ-Notations%20(2).pdf)