From 1 January 2026, the regulation of firefighting foams on ships will start to catch up with the global rejection of perfluoro-octane sulfonic acid (PFOS).
From that date, the use of PFOS will be prohibited onboard new ships, with existing vessels needing to replace them by their first survey thereafter.
Persistent Organic Pollutants
Recognized as Persistent Organic Pollutants (POPs), PFOS was discontinued by major US chemical producers over a decade ago under Environmental Protection Agency pressure, with their use also tightly restricted in the EU.
Where firefighting foams are concerned, however, lack of maritime restriction has seen the use of these durable compounds persist, even though the International Agency for Research on Cancer classifies them as “carcinogenic to humans.”
Maritime schedule
Requiring removal, disposal, and replacement of existing vessels by their first survey within five years on 1 January 2026
Once new regulations on PFOS in firefighting foams enter into force, Port State Control is likely to ensure that they have the “teeth” that some other areas of maritime legislation lack.
Even so, at first sight, the maritime schedule to phase out PFOS appears manageable. Requiring removal, disposal, and replacement by existing vessels by their first survey within five years on 1 January 2026, the job is one for scheduled drydocking. But the prospect of a pedestrian, if orderly maritime phase-out for these ‘forever chemicals’ in firefighting foams is fast evaporating.
Guidance covering marine pollution
First, while marine insurers continue to provide cover for firefighting systems holding PFOS, the latest guidance indicates that this no longer extends to claims covering marine pollution.
Second, regional regulators have accelerated their restriction of another hazardous compound - polyfluoroalkyl substances (PFAS) – which are also widely used in foam firefighting systems on board vessels and offshore platforms.
Firefighting foam sea change
In June 2023, the European Chemicals Agency recommended an EU ban on PFAS in firefighting foams. EPA also issued new reporting rules covering the manufacture and importation of PFAS in the U.S. in October 2023, as one of several measures aiming to accelerate their phase-out.
Threats of outright bans on PFAS are also under consideration in several European countries, Canada, and Australia. As a consequence, ship owners and managers are learning that the supply of firefighting foams which include PFAS – let alone PFOS - is drying up.
life-saving appliances
The company reports that five pioneering marine foam OEMs have discontinued products that include PFAS during 2024
VIKING Life-Saving Equipment is the industry’s pioneering supplier of life-saving appliances and also offers full foam inspection, replacement, and certification services. The company reports that five pioneering marine foam OEMs have discontinued products that include PFAS during 2024.
“Shipping is only a minor consumer of these products, and what is becoming clear is that rather than legislation, the driver for transition to different types of firefighting foams has quickly become OEMs stopping production,” says William Gielen, Global Director of Marine Fire Service.
PFAS
Some suggest that as many as 40,000 ships continue to carry firefighting foams that contain PFAS. They include oil tankers, chemical tankers, rigs, offshore vessels, and engine room systems on a wider pool of vessels.
“Owners and operators must get ahead of developments and factor in the switch to fluorine-free foams now,” Gielen emphasizes. “I don’t think people realize that if foam onboard is condemned from now on or if they need a top, to comply with existing regulations it’s already an issue.”
First responder
VIKING has undertaken numerous foam replacement projects to date, in Asia, Europe, and the Middle East, securing extensive knowledge of the testing, logistics, installation, disposal, and certification processes involved.
Replacement foams are readily available, while VIKING has its laboratory to sample and test the products that are succeeding those containing PFOS and PFAS.
Awareness campaign
Owners need to be aware that deep cleaning of shipboard systems is required to eradicate all traces
However, the life-saving specialist’s awareness campaign also highlights that replacing foams entails work that must be planned and scheduled for drydocking to avoid disruption to operating or charter obligations. Cargo vessels can’t sail without adequate firefighting systems, Gielen points out.
Owners need to be aware that deep cleaning of shipboard systems is required to eradicate all traces of outgoing compounds, he says. Systems will need recalibration for higher viscosity foams, and even re-engineering to include different pump types. Class approvals might also be necessary.
Certification management
“Because this is a new requirement, class sign-off on new systems specifications can take longer than expected,” he adds.
"In a new firefighting foam landscape, there is a benefit in having VIKING involved all through the process," adds Gielen. The company has made arrangements with certified disposal companies to take care of the foams that need replacing, for example, through their incineration and certification management.
Chain of responsibility
“Disposal of old foams is a more significant issue than many will be expecting,” he says, “Some ports don’t have the facilities, for example, while auditing the process is part of the regulatory obligation."
"While we are not a disposal company ourselves, we see this as a critical part of managing the full chain of responsibility for a new mandatory requirement.”