PFOS Firefighting Foam on Ships: The 2026 Survey Evidence File
Identify the firefighting media actually carried, the applicable 2026 prohibition and survey timing, and the evidence required by the flag Administration or authorised surveyor.
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What should a shipowner document about PFOS firefighting foam?
Identify the firefighting media actually carried, the applicable 2026 prohibition and survey timing, and the evidence required by the flag Administration or authorised surveyor. Keep manufacturer information, system records and any replacement work traceable. A foam purchase invoice alone does not prove that every onboard system, portable extinguisher and stored reserve meets the applicable requirements.
Check applicability before planning the work
The U.S. Coast Guard's policy announcement on SOLAS PFOS guidance provides an official reference for the prohibition and related guidance. Flag, vessel construction and survey requirements must be checked for the particular ship. PFOS and the broader family of PFAS should not be treated as interchangeable regulatory labels.
Use competent technical support to determine the required evidence and work. This article is not a procedure for sampling, draining, replacing or disposing of firefighting media. Those activities can affect fire protection, personnel safety and environmental compliance.
Build the inventory before the survey
| Item | Evidence to locate |
|---|---|
| Fixed systems | System identity, media details and service history |
| Portable equipment | Inventory and relevant manufacturer documentation |
| Stored reserves | Location, batch identity and intended use |
| Compliance evidence | Required declaration or testing information |
| Replacement work | Approved scope, contractor records and acceptance |
Make sure the inventory covers stores as well as installed equipment. A system may have been serviced using a different batch from the reserve carried aboard. Reconcile the documentation with physical identification through the appropriate inspection process rather than assuming that all containers hold the same product.
A fictional evidence gap
A ship receives replacement foam but its records do not establish what remains in a separate reserve locker. The survey preparation file should identify the unresolved stock and obtain the necessary technical confirmation. Filing the new invoice under “compliant” leaves the underlying question unanswered.
Similarly, a product substitution may need review for compatibility and performance within the particular system. Do not infer that a chemical description or environmental benefit alone demonstrates suitability for the installed fire-protection arrangement.
Tell underwriters about relevant changes
If fire-protection equipment is unavailable, modified or subject to significant remedial work, consider the disclosure and notification requirements of the vessel's cover. Regulatory compliance expenditure and an insured damage claim are different matters. A policy should not be assumed to pay routine replacement costs merely because a rule changes.
Read the machinery and operational risk guide, review hull and machinery enquiries, and submit the vessel's actual equipment or operating change where insurance assessment is needed.
Key takeaways
- Inventory installed media and reserves together.
- Obtain vessel-specific technical and survey confirmation.
- Keep compliance work separate from assumptions about insurance payment.
Frequently asked questions
What should a shipowner document about PFOS firefighting foam?
Identify the firefighting media actually carried, the applicable 2026 prohibition and survey timing, and the evidence required by the flag Administration or authorised surveyor. Keep manufacturer information, system records and any replacement work traceable. A foam purchase invoice alone does not prove that every onboard system, portable extinguisher and stored reserve meets the applicable requirements.
Sources & further reading
General information, not a coverage determination or offer. Actual cover is subject to policy wording, insurer terms, underwriting and applicable law.