Foam analysis and conversion to PFOS-free foam
Periodic foam testing and complete conversion to PFOS-free foam: draining, cleaning, refilling and the documents the surveyor will ask for.
Since 1 January 2026, SOLAS no longer permits fire-extinguishing media containing PFOS (above 10 mg/kg). Ships whose keels are laid on or after that date may not use or store such media at all; existing ships must be free of them by their first survey on or after that date. Many older ships still have the original concentrate in the foam tank.
The flag state or class verifies this through the manufacturer's declaration or a laboratory report, so the documents matter as much as the foam itself. We take care of the entire changeover: testing, draining, cleaning, refilling and documentation.
Scope
We start with what you have: fixed tanks, portable foam applicators and foam fire extinguishers, with their manufacturer, batch and certificates. Often this settles the question; if it does not, we test.
Samples are taken from the tank and sent to an accredited laboratory for PFOS content and the usual performance parameters.
The old concentrate is pumped out, collected and handed over for disposal ashore, with waste documents for your records.
The tank, proportioner and lines are flushed so that residues do not mix with the new foam.
PFOS-free concentrate suited to your system: not the cheapest drum, but the right type, the right proportioning ratio and the right approval.
The manufacturer's original PFOS-free declaration, test reports and disposal records, plus the information needed for your logbook entry and IHM update.
Intervals
| Equipment / task | Interval | Basis |
|---|---|---|
| Removal of PFOS-containing foam (existing ships) | By the first survey on or after 1 January 2026 | SOLAS II-2, Res. MSC.532(107) |
| Evidence that the foam is PFOS-free (declaration or laboratory report) | New ships at delivery; existing ships by the first survey on or after 1 January 2026 | SOLAS II-2/10.11, MSC.1/Circ.1694 |
| Low-expansion foam concentrate analysis | First within 3 years of delivery to the ship, then annually | MSC.1/Circ.1312 |
| High-expansion foam concentrate analysis | First after 3 years, then annually | MSC/Circ.670 |
What you receive
- Laboratory report for the old and the new concentrate
- The manufacturer's PFOS-free declaration, as issued by the manufacturer
- Disposal record for the foam removed from the system
- Service report signed on board by the master or chief officer
- Photos and clear notes for every unit that fails inspection, together with a repair quotation
Applicable rules
- SOLAS II-2/1 and II-2/10
- Res. MSC.532(107)
- Res. MSC.536(107) and MSC.537(107) (HSC)
- MSC.1/Circ.1694
- MSC.1/Circ.1312
- MSC/Circ.670
Frequently asked questions
Can we just top up with PFOS-free foam?
No. Mixing leaves PFOS in the system, and many foams are not compatible with one another. The old concentrate must first be drained and the system cleaned.
Will a fluorine-free foam work in our system?
Sometimes, but not always. Fluorine-free foams may need different proportioning ratios and are not approved for every application. We check your system's design before recommending a foam.
Is PFOS-free the same as PFAS-free?
No. SOLAS bans only PFOS; other fluorinated foams are still permitted under SOLAS. The EU is phasing out PFAS in fire-fighting foams under Regulation (EU) 2025/1988, so if the foam has to be replaced anyway, a fluorine-free foam is worth considering.