britanniapandi.com From 1 January 2026, a prohibition on the use or storage of fire extinguishing media containing Perfluorooctane sulfonic acid (PFOS) will take effect. Amendments to SOLAS Chapter II-2, and the HighSpeed Craft (HSC) Codes (1994 and 2000) will be applicable to both existing and new build ships. TThe amendments mean that ships constructed on or after 1 January 2026 will be prohibited from using or storing fire extinguishing media containing PFOS (defined as having a concentration of PFOS above 10 mg/kg). Existing ships must meet this requirement by the time of their first survey (annual, periodical, or renewal) after 1 January 2026. Proof will be required to demonstrate that any fire fighting medium, such as fire-fighting foam is compliant. This will take the form of a declaration from the maker, and/or laboratory test results, as necessary. The International Maritime Organization (IMO) has produced Unified Interpretations (MSC.1/Circ.1694) explaining the requirements. Any PFOS-containing substances shall only be disposed of at appropriate shore-base reception facilities. The IMO have indicated that the GISIS module will be updated to provide details of approved reception facilities, although no date has been provided for that function yet. PFOS may be recorded in a ship’s Inventory of Hazardous Materials (IHM) Part 1 in compliance with the European Union Ship Recycling Regulation, and disposal would require update of the inventory also. A useful summary of the amendments by a leading classification society, including links to the official IMO Resolutions can be found here. LOSS PREVENTION UPDATE PROHIBITION ON THE USE OR STORAGE OF FIRE EXTINGUISHING MEDIA CONTAINING PERFLUOROOCTANE SULFONIC ACID (PFOS) 1 // SEPTEMBER 2025 FURTHER INFORMATION For further information, please do not hesitate to email lossprevention@tindallriley.com. DISCLAIMER THIS LOSS PREVENTION UPDATE IS PUBLISHED BY THE BRITANNIA STEAM SHIP INSURANCE ASSOCIATION EUROPE (THE ASSOCIATION). Whilst the information is believed to be correct at the date of publication, the Association cannot, and does not, assume any responsibility for the completeness or accuracy of that information. The content of this publication does not constitute legal advice and Members should always contact the Association for specific advice on a particular matter.