ISM Info

Use or storage of extinguishing media containing PFOS

With the latest SOLAS amendments, the IMO prohibits the use or storage of extinguishing media containing perfluorooctane sulfonic acid (PFOS).

The IMO amended the regulations II-2/1 and II-2/10 SOLAS in order to protect the crew against exposure to this dangerous substance used in fire-fighting systems as well as to minimize the impact on the environment. This primarily affects fire-extinguishing foams in stationary and mobile systems and in portable fire extinguishers.

Fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS) shall be removed from the ship and delivered to appropriate shore-based reception facilities.

These changes apply to ships constructed on or after 1 January 2026. All ships constructed before 1 January 2026 shall comply to this requirement not later than the date of the first survey on or after 1 January 2026.

At the same time, there are changes to the 1994/2000 High-Speed Craft Code (HSC), Chapter 7.

With the attached circular MSC.1/Circ.1694 of 4 July 2025, the IMO provides unified interpretations (UI) and thus gives guidance on compliance matters.

Newly built ships may only be equipped with a certified, PFOS-free extinguishing medium. For the extinguishing media used on existing ships, proof that the extinguishing medium is free of PFOS must be provided, for example an approval certificate or a laboratory test – otherwise the extinguishing medium needs to be replaced. In order to avoid PFOS contamination, please note that stationary systems may need to be cleaned when replacing the extinguishing agent.

If you need to dispose of media containing PFOS, please ensure that you obtain suitable documentation and keep complete records, including entries in the ship's logbook. You may need this to prove that you have complied with the disposal requirements.

Additional information:

  • Reference IMO resolutions. MSC.532(107) - SOLAS, MSC.536(107) - 1994 HSC Code, MSC.537(107) - 2000 HSC Code.
  • First survey: the annual, periodical or renewal survey, whichever is due first (e.g. cargo ship safety equipment certificate, cargo ship safety certificate, passenger ship safety
    certificate, or high-speed craft safety certificate).
  • New or replacement extinguishing media shall be marked as PFOS free. The extinguishing media shall be approved and certified in accordance with the Implementing Regulation of the EU Marine Equipment Directive (MED). These include the FSS Code (IMO resolution MSC.98(73)) and IMO circulars MSC/Circ.670 and MSC.1/Circ.1312.