IMO REGULATORY UPDATE: IN-DEPTH ANALYSIS OF THE PFOS BAN IN SHIPBOARD FIRE-FIGHTING SYSTEMS EFFECTIVE FROM 01 JANUARY 2026

I. Introduction: IMO Directive on Phasing Out PFOS in Maritime Fire-Fighting Systems

Amid growing global concern over the environmental and health impacts of persistent organic pollutants (POPs), the international maritime community is taking decisive steps to mitigate risks associated with hazardous chemicals. One such substance, Perfluorooctane Sulfonic Acid (PFOS), has been identified as a major threat due to its persistence, bioaccumulative nature, and toxicity. Recognising these risks, the International Maritime Organization (IMO), through the Maritime Safety Committee (MSC), has issued a significant directive to eliminate the use of PFOS in shipboard fire-fighting systems.

This action by the IMO is not an isolated measure, but rather aligns with broader international efforts to control dangerous POPs. The Stockholm Convention on Persistent Organic Pollutants, a global treaty, has spearheaded the drive to eliminate PFOS since 2009. The IMO’s decision, formalised through amendments adopted at MSC 107, brings maritime regulations in line with these international environmental accords, signalling a strong commitment to maritime safety and environmental stewardship.

The core objective of the IMO’s PFOS ban is twofold: to safeguard the health and safety of seafarers from potential exposure to hazardous chemicals during fire-fighting operations, and to minimise the adverse environmental impacts of these substances on the marine environment and broader ecosystems. These chemicals, often referred to as “forever chemicals” due to their resistance to degradation, present long-term challenges that require proactive management measures.

This report aims to provide a comprehensive analysis of the upcoming IMO PFOS ban. It will delve into the nature of PFOS and the associated risks, closely examine the regulatory details of the IMO amendments, outline the responsibilities of various stakeholders, assess viable alternatives to PFOS-based fire-fighting foams, propose appropriate handling and disposal procedures, and discuss the potential challenges and costs of compliance within the maritime sector. The goal is to equip maritime stakeholders—particularly in Vietnam—with the necessary knowledge to navigate this critical regulatory transition effectively.

II. Perfluorooctane Sulfonic Acid (PFOS): Understanding the Hazard

To fully appreciate the significance of the IMO ban, it is essential to understand the nature of Perfluorooctane Sulfonic Acid (PFOS) and the substantial risks it poses to human health and the environment.

• Chemical Profile: PFOS and the PFAS FamilyPFOS is a synthetic, man-made chemical that belongs to a broader class known as per- and polyfluoroalkyl substances (PFAS). This group comprises thousands of compounds characterised by extremely stable carbon-fluorine bonds. The strength of these bonds imparts desirable properties to PFOS and other PFAS, such as resistance to heat, oil, and water—yet this same stability makes them remarkably persistent in the environment. They are commonly referred to as “forever chemicals” due to their resistance to natural degradation through metabolic, hydrolytic, or photolytic processes. Chemically, PFOS possesses both hydrophobic (water-repelling) and hydrophilic (water-attracting) functional groups, enabling it to act as a surfactant. It is moderately water-soluble and non-volatile. These properties, combined with its high stability and low surface tension, have historically led to its widespread use in a range of industrial and consumer applications. Most notably, PFOS was a key ingredient in Scotchgard fabric protectors and was extensively used in aqueous film-forming foams (AFFF)—a highly effective agent for extinguishing flammable liquid (Class B) fires commonly encountered onboard ships.
• Environmental and Health RisksPFOS’s extreme persistence is a primary environmental concern. Once released into the environment, it remains indefinitely, contaminating soil, surface water, and groundwater. Due to its mobility in water, it can be transported across vast distances, resulting in its detection even in remote areas such as the Arctic and Antarctic.Beyond its persistence, PFOS also exhibits significant bioaccumulative properties. It accumulates in the tissues of living organisms, including humans and wildlife, and its concentrations increase as it moves up the food chain (a process known as biomagnification). In humans, PFOS primarily accumulates in the serum, kidneys, and liver, with an estimated biological half-life of about three years—meaning it takes several years for the body to eliminate just half of the accumulated amount. Exposure to PFOS and other PFAS has been associated with a wide range of adverse health effects. Studies conducted by agencies such as the U.S. Environmental Protection Agency (EPA), the Centers for Disease Control and Prevention (CDC), and independent researchers have indicated potential links between PFOS/PFAS exposure and serious health outcomes. These include increased risk of certain cancers (such as kidney, testicular, liver, thyroid, and bladder cancers), developmental toxicity (e.g., growth delays in children), reproductive harm (e.g., preeclampsia, preterm birth, reduced fertility), immune system suppression, thyroid disease, liver damage, elevated cholesterol, chronic kidney disease, obesity, and hypertension. Humans can be exposed through multiple pathways, including consumption of contaminated water or food, use of consumer products containing PFAS, and occupational exposure.
• Global Context: The Stockholm Convention Ban (2009)In light of these hazards, the international community took action through the Stockholm Convention on Persistent Organic Pollutants. Entering into force in 2004, this treaty aims to eliminate or restrict the production and use of the world’s most hazardous and persistent chemicals. In May 2009, PFOS, its salts, and PFOSF (perfluorooctane sulfonyl fluoride) were added to Annex B of the Convention. This listing was based on scientific evidence of PFOS’s persistence, bioaccumulation, potential for long-range environmental transport (LRET), and toxicity. Inclusion in Annex B mandates strict restrictions on the production and use of PFOS, allowing only specific, acceptable purposes or exemptions—which have been increasingly narrowed over time. The IMO’s decision to ban PFOS in shipboard fire-fighting systems should not be viewed as an isolated maritime regulation. Rather, it is part of a broader and ongoing global regulatory trend, driven by expanding scientific understanding and public awareness of the risks associated with PFAS—initiated by the Stockholm Convention. This connection underscores that maritime regulations are now aligning with broader environmental standards. Furthermore, it suggests that future restrictions on other PFAS (such as PFOA, which has also been restricted under the Stockholm Convention in maritime applications) are entirely plausible. This reality reinforces the need for a strategic, potentially precautionary approach to replacing fire-fighting foams—focusing not only on PFOS compliance but also on long-term sustainability and future-proofing against further regulatory changes.

III. In-Depth Regulatory Analysis: IMO Resolutions and SOLAS Amendments

The ban on PFOS in marine firefighting systems has been established through a series of amendments to key IMO legal instruments, adopted by the Maritime Safety Committee (MSC) at its 107th session in May/June 2023. Verifying these specific amendments is essential to understand the legal foundation of the ban.

Verification of the Ban:
The resolutions formalizing the PFOS ban include:

• Resolution MSC.532(107): This resolution amends the International Convention for the Safety of Life at Sea (SOLAS), 1974, specifically Chapter II-2 relating to Construction – Fire protection, fire detection and fire extinction. It introduces new requirements under Regulation 10 (Firefighting) by adding a new paragraph 11 entitled “Restriction on fire-extinguishing media” and paragraph 2.10 concerning application to existing ships. This resolution also includes unrelated amendments, such as requirements for lifting appliances, electronic inclinometers, and the application of the Polar Code.
• Resolution MSC.536(107): This amendment applies to the 1994 International Code of Safety for High-Speed Craft (1994 HSC Code). It revises Chapter 7 (Fire Safety), Regulation 7.9 (Miscellaneous) to incorporate PFOS restrictions, specifically through the newly added paragraph 7.9.4.1.
• Resolution MSC.537(107): Similar to MSC.536(107), this resolution amends the 2000 International Code of Safety for High-Speed Craft (2000 HSC Code). It also modifies Chapter 7, Regulation 7.9 by adding paragraph 7.9.4.1 to prohibit PFOS.

Core Amendments: SOLAS Chapter II-2, Regulation 10 and the HSC Codes:
At the heart of these amendments is the introduction of a clear and unambiguous requirement within both SOLAS and the HSC Codes:

“The use or storage of fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS) shall be prohibited.”

It is important to note that the term “fire-extinguishing media” explicitly includes firefighting foams used in both fixed systems (e.g., deck systems, engine room systems) and portable firefighting equipment (e.g., fire extinguishers). The simultaneous application of the amendments to both SOLAS and the HSC Codes ensures a harmonized approach across different ship types, including high-speed craft, in accordance with their respective regulatory frameworks.

Prohibited Activities:
The regulation expressly prohibits both actions: the use and storage of PFOS-containing fire-extinguishing media on board ships after the compliance date enters into force.

The use of the phrase “use or storage” is comprehensive. It not only bans the active deployment of PFOS-based foam in firefighting systems but also forbids retaining such substances on board for any purpose—even if reserved in storage or disconnected from operational systems. This broad prohibition underscores the IMO’s intent to fully eliminate PFOS from the shipboard environment due to its inherent hazards, ensuring that no PFOS remains onboard beyond the compliance deadline. Full removal, not merely cessation of active use, is therefore mandatory.

IV. Compliance Pathway: Scope of Application, Timeline, and the “First Survey”

Navigating the compliance requirements of the PFOS ban demands a clear understanding of the scope of application, key deadlines, and the interpretation of the regulatory term “first survey.”

Scope of Application:
The PFOS ban has broad applicability across the maritime sector:

• SOLAS Ships: The regulation applies to all ships subject to the requirements of SOLAS Chapter II-2. This typically includes all passenger ships regardless of size and cargo ships of 500 gross tonnage and above engaged on international voyages.
• High-Speed Craft (HSC): Ships subject to the 1994 and 2000 HSC Codes must also comply with the PFOS ban, as outlined in the respective amendments (MSC.536(107) and MSC.537(107)).
• Other Units: The ban also extends to other mobile units, including Mobile Offshore Drilling Units (MODUs).
• Systems and Equipment: The ban applies to both fixed firefighting systems and portable firefighting equipment containing PFOS.

The inclusion of MODUs and the broad definition of “ships” under SOLAS and the HSC Codes means this regulation affects a wide and diverse segment of the maritime industry, beyond just conventional cargo and passenger vessels. This broad scope implies far-reaching impact and a substantial global demand for PFOS-free foam alternatives, cleaning services, and disposal infrastructure.

Timeline for New Ships and New Installations (From 1 January 2026):

• New Ships: Ships constructed (i.e., keel laid or at a similar stage of construction) on or after 1 January 2026 must comply with the PFOS ban upon delivery. The use or storage of PFOS-containing fire-extinguishing media is prohibited on these ships.
• New Installations: Any firefighting system or equipment installed on any ship on or after 1 January 2026 must be PFOS-free.

Timeline for Existing Ships (Before 1 January 2026):
This is the most critical aspect for the majority of the existing fleet.

• Compliance Deadline: Ships constructed before 1 January 2026 must comply with the PFOS ban (i.e., complete removal of all PFOS on board) no later than the first survey conducted on or after 1 January 2026.

Definition of “First Survey”: Interpretation per MSC.1/Circ.1290

The SOLAS and HSC amendments explicitly refer to the “Unified interpretation of the term ‘first survey’ referred to in SOLAS regulations” (MSC.1/Circ.1290). This circular, approved by the MSC in December 2008, provides the official definition:

• Definition: Unless expressly provided otherwise, the term “first survey” means the first annual survey, the first periodical survey, or the first renewal survey, whichever comes first after the date specified in the relevant regulation (in this case, 1 January 2026).
• Ships Under Construction: For ships under construction with keel laid before 1 January 2026 but delivered after that date, the initial survey is considered the “first survey” for compliance purposes.
• No Change: The “first survey” date is not altered by any change in flag, nor by any unscheduled, additional, or occasional surveys or inspections.

Linking compliance deadlines to the “first survey” creates a flexible implementation window for the existing fleet. Instead of imposing a single fixed date for all ships, each vessel’s compliance deadline is tied to its specific survey schedule under SOLAS (annual, periodical, or renewal). Since renewal surveys occur every five years, a ship with a late-cycle renewal survey (e.g., December 2030) may technically delay compliance until then—provided no annual or periodical survey is due before that date. This flexibility requires shipowners to accurately track the survey schedules of each vessel and plan system replacement or cleaning during scheduled drydockings. This approach differs from regulations that impose a rigid, fixed compliance date but demands careful individualized management and forward planning.

V. Responsibilities of Stakeholders in PFOS Elimination

The successful implementation of the IMO’s PFOS ban requires coordinated efforts and clear responsibilities from various stakeholders in the maritime industry. Understanding the roles and obligations of each party is essential to ensure a smooth transition and compliance with the regulations.

Shipowners and Operators:
The primary responsibility for ensuring compliance lies with shipowners and operators. Their specific obligations include:

• Adherence to Deadlines: Ensure that their vessels comply with the PFOS ban no later than the first survey date on or after January 1, 2026.
• Foam Replacement: Plan and implement the timely replacement of all PFOS-containing firefighting foams with approved, PFOS-free alternatives.
• System Cleaning: Ensure that tanks and associated piping systems (especially AFFF systems) are thoroughly cleaned and decontaminated to remove any PFOS residues before recharging with new foam.
• Procurement: Purchase only firefighting foams that have been approved and certified according to relevant IMO guidelines, with certificates confirming the absence of PFOS.
• Handling: Arrange for the safe collection and transfer of removed PFOS-containing firefighting foams to suitable shore-based reception facilities for responsible disposal.
• Testing: If unsure about the composition of existing foam, shipowners should arrange for sampling and testing by specialized laboratories. This can be done during regular foam concentration controls or when compiling the Inventory of Hazardous Materials (IHM) Part I.
• Record Keeping: Record the disposal and transfer of PFOS to shore-based reception facilities in the vessel’s official logbook and retain the approval certificates for the replacement foam.
• Coordination: Coordinate with port officials to ensure proper disposal before the required deadline.

Shipyards:
Shipyards are responsible for ensuring compliance with PFOS requirements for newbuild vessels:

• Newbuild Vessels: Ensure that all vessels built and delivered on or after January 1, 2026, are equipped with firefighting systems and foams that are completely PFOS-free.
• Installation: Install only IMO-approved, PFOS-free firefighting systems and foams.

Manufacturers (Foam/Firefighting Equipment):
Manufacturers play a key role in providing compliant solutions:

• Product Development: Develop, test, and supply effective PFOS-free firefighting foam alternatives (SFFF/F3) that are IMO-approved for maritime applications.
• Certification and Documentation: Provide clear documentation and type approval certificates confirming that products are PFOS-free and comply with IMO circulars (e.g., MSC.1/Circ.1312, MSC/Circ.670).
• Technical Support: Provide technical support during the transition, including recommended cleaning procedures or system compatibility assessments.

National Maritime Authorities (Flag States) & Recognized Organizations (ROs)/Classification Societies:
Regulatory and oversight bodies are responsible for monitoring compliance:

• Verification: Verify compliance with the PFOS ban during vessel surveys (annual, periodic, newbuild, initial).
• Certification: Issue or confirm relevant certificates reflecting compliance status.
• Guidance: Provide industry guidance, clarifications, and circulars regarding regulation implementation.
• Approval: Approve laboratories and standards for foam composition analysis.

Port Reception Facility (PRF) Providers:
PRF providers are an essential link in the waste management chain:

• Facility Provision: Ensure that suitable, adequate reception facilities are available to safely handle and manage PFOS-containing waste in an environmentally responsible manner, in compliance with MARPOL obligations.

This clear allocation of responsibilities underscores the collaborative nature of maritime regulatory compliance. Success depends on the proactive and coordinated actions of all parties—from shipowners ensuring onboard compliance to manufacturers providing appropriate replacement solutions and regulators verifying compliance.

VI. Alternatives to PFOS-Free Firefighting Foam

The PFOS ban requires the maritime industry to transition to alternative firefighting foams. The market currently offers several fluorine-free options, often referred to as Fluorine-Free Foams (F3) or Synthetic Fluorine-Free Foams (SFFF).

Introduction to Fluorine-Free Foams (F3/SFFF):
F3/SFFF achieves firefighting effectiveness by using fluorine-free surfactant mixtures, typically hydrocarbons. Unlike AFFF foams that contain fluorine (including PFOS-containing foams), which form a thin water film on the fuel surface, F3 foams generally work by cooling the fuel and creating a thick foam layer that prevents vapor release and oxygen exposure. Due to their different operating mechanisms, their performance characteristics may differ from traditional AFFF.

IMO Approval Standards and Performance:
Any alternative foam used in fixed systems onboard vessels must be approved by the Flag State Administration in accordance with IMO-accepted testing standards. The primary IMO circulars governing these standards are:

• MSC.1/Circ.1312 (amended): “Amendments to the Guidelines on performance and testing standards for low expansion foam firefighting systems.” This circular sets requirements for low-expansion foam systems protecting engine rooms and oil tankers, including tests for firefighting effectiveness, compatibility, stability, and other physical characteristics.
• MSC/Circ.670: “Guidelines for approval of foam-based firefighting systems equivalent to those prescribed by SOLAS 74 for engine rooms.” This circular specifically addresses medium and high-expansion foam systems used in engine rooms as an alternative to SOLAS-prescribed systems.

It is crucial that the selected F3 foams meet the performance standards outlined in these circulars and are approved by the Flag State of the vessel or a Recognized Organization (RO) acting on behalf of the Flag State. The approval must specify that the product is PFOS-free.

Factors to Consider When Selecting an Alternative Foam: Choosing the appropriate F3/SFFF involves considering several factors beyond mere approval:

• Firefighting Effectiveness: The performance of different F3 foams can vary depending on fuel type, fire size, and application techniques. It is essential to choose a foam proven effective for specific hazards onboard (e.g., hydrocarbon fires in engine rooms, deck fires on oil tankers). Some F3 foams may require higher application rates or longer application times than AFFF to achieve similar control.
• System Compatibility: This is a critical factor. F3 foams have different physical properties (e.g., viscosity) compared to AFFF. It is necessary to assess whether the existing foam systems (proportioning devices, nozzles, piping) are compatible with the chosen F3 foam. In some cases, hardware modifications or replacements may be required to ensure proper operation. Manufacturers often provide guidance on compatibility.
• Cleaning Requirements: Due to the persistence of PFOS, thorough cleaning of systems before charging with F3 foam is critical to avoid cross-contamination. The cleaning procedures recommended by foam manufacturers and classification societies must be strictly followed.
• Stability and Shelf Life: Evaluate the certified shelf life of the F3 foam and its storage requirements.
• Availability and Cost: Consider the availability of the selected foam at major ports, as well as the cost of procurement, installation, and ongoing maintenance. F3 foams may have higher initial costs than AFFF.

Switching to F3 foams is not just a matter of “replacing the old with the new.” It requires careful technical evaluation of the existing system and the proposed alternative foam to ensure continued firefighting effectiveness and compliance with IMO regulations. Consulting foam manufacturers, classification societies, and experienced service providers is strongly recommended during the selection and transition process.

VII. Handling and Disposal of PFOS-Containing Foam

The safe and responsible disposal of expired PFOS-containing firefighting foam from vessels is a crucial aspect of complying with the IMO ban. Due to the hazardous nature of PFOS, improper handling can lead to environmental pollution and health risks.

IMO and MARPOL Requirements:
IMO amendments (e.g., MSC.532(107)) clearly state that if PFOS is present on a vessel, it must be “delivered to appropriate reception facilities at port.” This requirement aligns with the broader principles of the International Convention for the Prevention of Pollution from Ships (MARPOL). Although PFOS is not specifically classified in MARPOL’s annexes, its hazardous and persistent nature requires it to be handled as hazardous waste or a potential pollutant.

MARPOL Annex V (Garbage):
It can be argued that PFOS concentrate, in the form of waste from maintenance activities (e.g., tank cleaning), falls under the operational waste management provisions of Annex V, particularly regarding the discharge of harmful cleaning agents into the marine environment. Discharging PFOS into the sea is prohibited.

Port Reception Facilities (PRF) Responsibilities:
MARPOL member states are obligated to ensure the availability of sufficient port reception facilities (PRFs) to accept waste from ships without undue delay. This includes operational waste such as expired firefighting foam. PRFs must be equipped to manage these wastes in a safe and environmentally responsible manner.

Recommended Collection and Disposal Procedures: Handling and disposal of PFOS must follow strict procedures:

1. Identification: Confirm whether the foam contains PFOS through documentation (Material Safety Data Sheets – MSDS/SDS, approval certificates) or laboratory analysis if uncertain.
2. Planning: Coordinate with port agents and licensed PRF providers at the next port of call or during a scheduled dry-docking to arrange for PFOS-containing foam disposal. Confirm that the PRF is authorized and equipped to handle PFOS waste.
3. Collection: Removal of PFOS foam and wash water from tanks and pipes must be carried out by trained personnel using appropriate personal protective equipment (PPE) to avoid exposure. Liquid waste (concentrated foam and wash water) must be collected in suitable containers, clearly labeled.
4. Cleaning: Thorough cleaning of tanks and piping systems is essential. Cleaning procedures may involve multiple flushes with water or specific detergents as recommended by foam manufacturers or classification societies. The wash water also contains PFOS and must be collected for disposal.
5. Transfer: Transfer labeled containers of PFOS foam and wash water to authorized PRFs as per port and national regulations.
6. Documentation: Record the transfer in the Ship’s Garbage Record Book or other official logbook as required by national authorities. Collect receipts or documentation from the PRF confirming the waste acceptance. Keep this documentation onboard for inspection.

The Importance of Adequate Port Reception Facilities: The availability and capability of PRFs are key to successful compliance.

• Challenges: Not all ports may have facilities equipped to safely handle and dispose of PFAS/PFOS waste (e.g., through high-temperature incineration or other advanced treatment technologies). A lack of such facilities could create logistical and cost challenges for ship owners.
• Port State Responsibilities: Port states are obligated under MARPOL to ensure adequate facilities are available. Shipowners and industry stakeholders should liaise with port authorities and regulators to highlight the need for specialized PFOS disposal facilities.

Responsible Disposal:
Improper disposal, such as dumping into drainage systems or uncontrolled landfills, will lead to environmental pollution and violate environmental regulations. Choosing a reputable and licensed PRF is essential.
PFOS disposal is not just a regulatory requirement; it is an environmental responsibility. Following appropriate disposal procedures and using authorized facilities is critical to preventing further pollution by these “forever chemicals.”

VIII. Costs and Challenges for the Vietnamese Maritime Industry

The implementation of the IMO PFOS ban presents significant financial and operational challenges for the maritime industry, with Vietnam’s context being no exception.

Cost Analysis: Compliance with the PFOS ban incurs various costs for shipowners and operators:

1. Foam Replacement Costs:F3/SFFF foam typically has a higher upfront purchase price compared to traditional AFFF foams (including both obsolete PFOS-containing AFFF and more modern C6-based AFFF). Prices vary depending on the manufacturer, performance, and volume purchased.
2. System Cleaning Costs:Thoroughly cleaning and decontaminating tanks and piping systems to remove PFOS residues is a costly and time-consuming task. It requires specialized labor, equipment, cleaning agents, and may involve multiple flushes.
3. System Modifications Costs:As mentioned, some existing foam systems may not be fully compatible with the physical properties (e.g., viscosity) of F3 foam. This may require modifications or replacement of system components (e.g., dosing equipment, nozzles, piping), which can add significant costs.
4. Waste Disposal Costs:The collection, transport, and safe disposal of PFOS foam and contaminated wash water at licensed port reception facilities also incur costs. Hazardous waste disposal can be particularly expensive, especially if it requires specialized treatments like high-temperature incineration.
5. Operational Downtime Costs:Foam replacement, system cleaning, and potential modifications are typically carried out during scheduled dry-docking to minimize vessel downtime. However, if these activities take longer than expected or if unscheduled dry-docking is needed, the loss of revenue due to operational downtime can be significant.
6. Administrative and Inspection Costs:Costs associated with planning, project management, foam inspections (if needed), documentation updates, and ensuring compliance verification by classification societies.

The total cost for each vessel may vary significantly depending on the size and complexity of the firefighting foam system, the type and age of the vessel, the selected F3 foam, the extent of cleaning and modifications required, and local waste disposal costs. However, it is clear that this is a considerable investment for shipowners.

Potential Challenges:

Beyond costs, the Vietnamese maritime industry may face additional challenges:

1. Port Reception Facility (PRF) Availability:One potential challenge in Vietnam and the region is the availability of fully equipped and licensed PRFs capable of safely handling and disposing of PFOS waste. The lack of such facilities could force vessels to retain waste on board for extended periods or travel to other ports, increasing complexity and costs.
2. Availability of Replacement Foam and Technical Expertise:While the F3 foam market is growing, ensuring a stable supply of approved F3 foams suitable for specific vessel requirements in Vietnamese ports may pose logistical challenges. Additionally, there may be high demand for technicians and engineers experienced in transitioning to F3, cleaning systems, and assessing compatibility.
3. Cleaning and Modification Complexity:Ensuring systems are sufficiently cleaned to avoid contamination of new F3 foam with PFOS residues is critical but technically challenging. Identifying and implementing any necessary system modifications also requires technical expertise.
4. Awareness and Preparation:It is essential that all shipowners, operators, and stakeholders in Vietnam are fully aware of the requirements, deadlines, and necessary steps for compliance. Delays in planning and preparation could lead to last-minute rushes, higher costs, and potential compliance issues.
5. Burden on Smaller Shipowners:Smaller shipowners or those with older fleets may find the financial and technical burden of compliance particularly difficult.

Addressing these challenges requires a proactive approach from the Vietnamese maritime industry, including collaboration between shipowners, regulators (e.g., Vietnam Maritime Administration), port authorities, classification societies, and service providers. Information sharing, local capacity development (e.g., PRFs, technical expertise), and early planning will be key to overcoming these obstacles.

IX. Conclusion and Recommendations for the Vietnamese Maritime Industry

The upcoming IMO ban on the use and storage of PFOS-containing firefighting agents on ships, effective January 1, 2026, is an important step toward aligning maritime safety regulations with global environmental and health standards. Driven by scientific understanding of the persistence, bioaccumulation, and toxicity of PFOS, a “forever chemical” restricted under the Stockholm Convention, this new regulation reflects the maritime industry’s commitment to minimizing environmental impacts and safeguarding seafarers’ health.

Compliance requires a multifaceted approach. For existing vessels, deadlines are tied to the “first survey” (annual, periodic, or renewal) taking place on or after January 1, 2026, requiring shipowners to plan carefully based on each vessel’s survey schedule. The primary responsibility lies with shipowners and operators, who must ensure the replacement of PFOS foam with approved fluorine-free alternatives (F3/SFFF), thoroughly clean relevant systems, and responsibly dispose of PFOS waste through authorized port reception facilities. Shipyards, foam manufacturers, national authorities, classification societies, and PRF providers all play a crucial role in facilitating this transition.

The transition to F3/SFFF foam is not without its challenges. It requires careful assessment of existing system compatibility with the different physical properties of F3 foam, potentially leading to costly hardware modifications. The cleaning process to eliminate PFOS residues is complex and expensive. Moreover, the cost of F3 foam, PFOS waste disposal, and the availability of specialized PRFs present significant financial and logistical barriers, particularly for the Vietnamese maritime industry.

X. Recommendations for the Vietnamese Maritime Industry:

1. Increase Awareness and Disseminate Information: The Vietnam Maritime Administration, shipowners’ associations, and classification societies should actively disseminate detailed information about the PFOS ban, compliance requirements, deadlines, and F3 alternatives to all shipowners and operators in Vietnam. Workshops, webinars, and guidance publications can support this effort.
2. Early Planning and Assessment: Vietnamese shipowners should immediately identify vessels in their fleet with PFOS-containing firefighting systems. They need to determine the “first survey” date for each vessel after January 1, 2026, and begin planning for PFOS replacement, cleaning, and disposal, preferably in conjunction with scheduled dry-docking periods. Early assessment of system compatibility with potential F3 foams is crucial.
3. Assess and Develop Port Reception Facility (PRF) Capabilities: Vietnamese port authorities, in collaboration with the Ministry of Natural Resources and Environment, should assess existing capabilities to handle PFOS waste. Priority should be given to investing in or facilitating the development of appropriately licensed and equipped PRFs capable of safely and responsibly handling and disposing of PFOS waste according to international standards.
4. Cooperation and Expertise Sharing: Encourage collaboration between shipowners, foam suppliers, classification societies, and technical service providers. Sharing experience, best practices for cleaning and system modifications, as well as information on the performance and compatibility of different F3 foam types, will benefit the entire industry.
5. Research Alternative Solutions and Suppliers: Shipowners should research the various F3/SFFF foam types available in the market to ensure they meet IMO approval standards (MSC.1/Circ.1312, MSC/Circ.670) and are suitable for specific shipboard applications. Consulting with manufacturers and classification societies regarding compatibility and performance is essential.
6. Maintain Compliance Documentation: Keep meticulous records of PFOS removal, system cleaning, waste transfer to PRFs (including receipts), and approval certificates for new F3 foam. These documents will be critical during surveys by classification societies.
7. Consider Future PFAS Regulations: Recognize that PFOS is just one of many PFAS compounds under increasing regulatory scrutiny. When selecting alternative foams, consider fully PFAS-free products to avoid future compliance issues related to other PFAS compounds (such as PFOA or shorter-chain PFAS).

By proactively implementing these steps, the Vietnamese maritime industry can successfully navigate the transition away from PFOS, ensuring compliance with international regulations, protecting the marine environment, and maintaining the highest safety standards aboard its vessels. While challenges are real, early planning and cooperation will be key to successfully transitioning to a PFOS-free maritime firefighting future.

Compiled by Team Seafarer Club with Gemini AI.