Firefighting foam is one of the quiet pieces of equipment on a ship: it sits in a tank or a drum for years until the day it is needed. On 1 January 2026 that changed for a specific group of foams. Amendments to SOLAS Chapter II-2 now prohibit PFOS (perfluorooctane sulfonic acid) in the fire-extinguishing media carried on ships.
What the rule says
SAFETY4SEA’s 2026 regulatory agenda states that from 1 January 2026 fire-extinguishing systems and equipment must not use or store PFOS-containing media. It lists SOLAS ships, the 1994 and 2000 High-Speed Craft Codes, and fixed and portable fire-fighting systems as covered. The Deep Draft’s overview reads the change as applying to both new installations and foam stocks already on board.
PFOS is a persistent pollutant, which is why regulators are phasing it out of firefighting foams. How the transition applies to a particular existing ship can depend on flag State and class interpretation, so confirm it with them rather than assuming.
Where to look on board
- Fixed foam systems: deck foam on tankers, engine room and helideck systems, and the foam concentrate tanks that feed them.
- Portable and semi-portable units: foam extinguishers and applicator sets, drums and containers stored in fire lockers.
- Spare stock: reserve concentrate carried to top up systems after a test or a discharge.
How to find out what your foam contains
- Start with paperwork. The supplier’s safety data sheet and technical data sheet, and any manufacturer’s declaration, should state the foam type and whether it contains PFOS.
- Ask the supplier in writing when the paperwork is old, unclear or missing, and keep the reply with the ship’s fire safety documents.
- Do not rely on the label alone. An older AFFF concentrate may or may not contain PFOS. Only documentation or chemical analysis can tell you.
- Plan replacement early. Changing foam stocks needs planning, proper disposal of the old concentrate and updated documents, so start before the next survey, not after it.
Foam testing is a separate check
Separate from the PFOS question, foam concentrates should be tested periodically to confirm that they still perform. Berth Marine’s laboratory services include foam compound tests for a range of concentrates and a standard 72-hour turnaround for results. These tests check the condition and performance of the foam; identifying PFOS content depends on the manufacturer’s documentation and, where needed, specialist chemical analysis. Our team can also inspect the wider system as part of our fire fighting system service.
If you are unsure about the foam on one of your vessels, send us the vessel details and the foam data sheets and we will tell you what we can check on board.
This article is for information only and is not legal advice. Confirm the exact requirements with your flag State and class society.