Marine Advisory: 16/2024 - Guidance on the Prohibition of Use or Storage of Extinguishing Media Containing Perfluorooctane Sulfonic Acid (PFOS), on Ships and Other Vessels
08 July 2024
Marine Advisory 16/2024
08 July 2024
Marine Advisory: 16/2024
Subject: Guidance on the Prohibition of Use or Storage of Extinguishing Media Containing Perfluorooctane Sulfonic Acid (PFOS), on Ships and Other Vessels
To: Shipowners/Operators/Recognized Organizations/Masters:
Purpose
The purpose of this Marine Advisory is to inform shipowners, operators, and masters of the forthcoming SOLAS and High Speed Craft Code amendments that prohibit the use of fire extinguishing media (i.e. firefighting foams, etc.) containing perfluorooctane sulfonic acid (PFOS) on board ships and other vessels, including mobile offshore units, references (a) and (b) above.
Background
The Maritime Safety Committee, at its 107th session, adopted amendments to SOLAS Chapter II-2, Part C, Regulation 10 – Fire Fighting and the High-Speed Craft Code (HSC) Chapter 7 Part A, Regulation 7.9 which prohibit the use of firefighting foams containing perfluorooctane sulfonic acid (PFOS) on board ships and other vessels, including mobile offshore units. The purpose of the amendments is to protect persons on board against exposure to dangerous substances used in firefighting, as well as to minimize the impact of fire-extinguishing media that are deemed detrimental to the environment.
The amendments will enter into force on 1 January 2026.
Requirements
For ships and other vessels, including mobile offshore units constructed on or after 1 January 2026, the use or storage of extinguishing media containing perfluorooctane sulfonic acid (PFOS) is prohibited.
Ships and other vessels, including offshore mobile units constructed before 1 January 2026 shall comply with regulations prohibiting the use or storage of extinguishing media containing PFOS not later than the date of the first survey on or after 1 January 2026.
The term “first survey” as referenced by a regulation in the 1974 SOLAS Convention, as amended, means the first annual survey, the first periodical survey or the first renewal survey whichever is due first after the date specified in the relevant regulation.
The Administration recommends testing for PFOS when carrying out the periodical control of foam concentrates on board; or alternately, when developing the Inventory of Hazardous Materials (IHM) Part I, due no later than 26 June 2025.
When removed from a ship or other vessel, including offshore mobile units, PFOS shall be delivered to appropriate shore-based reception facilities. The removal and subsequent delivery to an appropriate shore-based reception facility shall be duly recorded in the ship’s official logbook.
Replacement extinguishing media should be approved and certificated in accordance with the applicable IMO guidelines. The extinguishing media approval certificate should clearly indicate the absence of PFOS in the media. High-expansion foam concentrate should be approved in accordance with MSC/Circ.670 and low-expansion foam in accordance with MSC.1/Circ.1312/Corr.1.
Questions regarding this guidance should be referred to RegsandStandards@liscr.com or telephone +1-703790-3434.
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