Effective January 1, 2026, the use or storage of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS) will be prohibited under SOLAS and the High-Speed Craft (HSC) Codes. Maritime insurer Gard warns that timely preparatory actions should be undertaken to ensure full compliance.
Gard said that perfluorooctane sulfonic acid is a persistent organic pollutant (POP) and a member of the broader class of perfluoroalkyl substances (PFAS), a group of synthetic chemicals known for their resistance to heat and their ability to repel oil and water. These properties have made PFAS widely used across numerous consumer and industrial applications, including fire-fighting foams. PFOS has historically been a key ingredient in aqueous film-forming foams (AFFF), which are used to extinguish flammable liquid (Class B) fires.
However, the same properties that makes PFOS effective in fire-fighting also contributes to significant environmental and health risks. Its use is subject to extensive regulation, including the Stockholm Convention on POPs.
Although the use of PFOS in fire-fighting foams has declined due to growing awareness of its persistence, potential toxicity, and resulting regulatory actions, it may still be permitted in certain jurisdictions and carried onboard vessels.
To protect individuals onboard ships from exposure to harmful substances and to minimise environmental impact, the IMO has adopted amendments to SOLAS Chapter II-2 and the 1994 and 2000 High-Speed Craft (HSC) Codes. These amendments prohibit the onboard use and storage of fire-extinguishing media containing PFOS in both fixed and portable fire-fighting systems and equipment, with the PFOS maximum allowable concentration limit set at 10 mg/kg (0.001 percent by weight).
The rules takes effect on January 1, 2026 and applies to both new and existing vessels. 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 January 1, 2026, with the term “first survey” interpreted in accordance with MSC.1/Circ.1290.
