How to document PFOS-free fire-extinguishing foam on board

Starting 1 January 2026, all merchant vessels must ensure that fire-extinguishing foams on board are entirely PFOS-free. During the first safety equipment survey after this deadline, attending surveyors will mandate strict verification of foam composition to avoid part-held surveys or the issuance of Conditions of Authority. Whether operating bulk carriers in Singapore or tankers in Rotterdam, crews must proactively replace legacy foams containing perfluorooctane sulfonic acid. Compliance is essential to maintain vessel seaworthiness and prevent costly operational delays during port state control inspections.

This regulatory shift stems from amendments to the International Convention for the Safety of Life at Sea (SOLAS), specifically Chapter II-2, which governs fire protection, detection, and extinction. The transition away from PFOS-containing foams is driven by environmental safety standards and the Stockholm Convention on Persistent Organic Pollutants. Compliance departments must ensure that all foam concentrates are accompanied by a formal statement of compliance or a certificate of analysis from the manufacturer. Failure to provide documented proof of chemical composition during annual surveys will result in non-conformity reports, potentially impacting a vessel's safety management system certification.

Chief engineers and second engineers bear the primary responsibility for documenting compliance during the transition period. These officers must conduct a thorough inventory of all foam stocks, ensuring that the product data sheets clearly state the absence of PFOS. They should organize these documents within the vessel’s fire safety equipment logbook for immediate presentation to surveyors. Maintaining clear records of foam replacement dates and chemical specifications is critical to ensuring a seamless and successful safety equipment survey.