The International Maritime Organization is closing a chapter that has shaped marine firefighting for nearly fifty years. Under Resolution MSC.532(107), the IMO has amended SOLAS Chapter II-2 together with the 1994 and 2000 High Speed Craft Codes to prohibit the use or storage of fire-extinguishing media that contain perfluorooctane sulfonic acid (PFOS) above 10 mg/kg (0.001% by weight). The amendments enter into force on 1 January 2026, and apply to both fixed fire-extinguishing systems and portable firefighting equipment, including stored foam concentrates carried for trailer-mounted and helideck units. For Thai operators running tankers, FSRUs, port firewater systems and offshore installations, the practical deadline is closer than the calendar suggests, because procurement, retrofit, ITM testing and crew training all need to be completed before the next Cargo Ship Safety Equipment Certificate (CSSEC) survey or class renewal that falls after 1 January 2026.
This post explains exactly what the ban covers, where Thai facilities trip up, and how a retrofit using FireDos GEN III water-driven proportioners together with a PFAS-free concentrate — whether from the BIOEX ECOPOL family or the VERSAGARD family by Perimeter Solutions — can be sequenced without taking the asset out of service for longer than necessary. For an NFPA 11 audit and design-density view of the same problem, see our NFPA 11 compliance guide for Thai sites, and for a head-to-head comparison of the two main PFAS-free foam families, see PFAS-free foam: what to test before specifying.
What the IMO 2026 PFOS rule changes
Under MSC.532(107), the prohibition applies to fixed foam systems on ships and offshore units, including engine-room foam, helideck foam, tanker deck foam and FSRU systems. It also drives the phase-out of legacy AFFF stocks held onboard for portable and trailer-mounted units. By the first survey on or after 1 January 2026, ship owners, managers and operators must hold documentary evidence that all firefighting foams within fixed and portable equipment are PFOS-free, and must arrange for safe disposal of any prohibited foam concentrate as hazardous waste.
Three things tend to be misunderstood:
- The ban is on the chemistry, not the brand. Switching foam suppliers without verifying PFAS content does not make a system compliant. The 10 mg/kg threshold means batch-level certificates, not marketing statements, are required.
- The proportioner matters as much as the foam. Older bladder-tank and balanced-pressure proportioners were calibrated and sealed for AR-AFFF. PFAS-free concentrates such as BIOEX ECOPOL Premium or VERSAGARD AS-100 3×3 are typically more viscous, are sometimes pseudoplastic, and behave differently at turn-down. Any concentrate change must therefore be tested against the proportioner before sign-off.
- Class and Flag State will ask for evidence. Expect to show foam type-approval certificates against IMO MSC.1/Circ.1312 for low-expansion foams, batch certificates with PFAS declaration, proportioning-rate test records under NFPA 25 (2023 edition), and proof that discharge devices still meet the original NFPA 11 design density.
Why this matters for the Thai market
Thailand’s exposure is unusually broad. The Sriracha refinery cluster, Map Ta Phut petrochemical zone, Laem Chabang and Songkhla port complexes, the offshore fields operated by national oil and gas companies, and the downstream tank farms run by major Thai oil refineries, petrochemical operators and tank-farm operators all rely on foam-based protection that interfaces with marine activity. A mis-sequenced retrofit, where the foam is replaced but the proportioner is not re-validated, can leave a tank farm or a jetty manifold non-compliant on the morning of a class survey.
The retrofit decision: foam, proportioner, or both?
For most Thai operators the honest answer is “both, in the right order”. Replacing AR-AFFF with a PFAS-free concentrate without checking the proportioner usually produces one of two failure modes: the proportioning rate drifts outside the NFPA 11 design band of 3% +0.3 / -0 percentage points, or the seal materials degrade against the new concentrate.
Why water-driven proportioning fits the transition
FireDos GEN III water-driven proportioners use firewater itself as the energy source. A water motor drives a positive-displacement plunger pump, and because each revolution of the water motor and the plunger pump has a fixed displacement, the proportioning rate is mechanically locked to the firewater flow. Three properties matter during the transition:
- Wide turndown up to 1:15. The FM Approved working envelope of the FD20000/3-S runs from 1,330 l/min to 20,000 l/min on a single proportioner. The same unit supplies small monitor calls and full-flow tank-rim pours without recalibration.
- Foam-agnostic operation. The FireDos FD2000, FD0000, FD10000 and FD20000 GEN III range supports AR-AFFF, AR-SFFF, FFF, Class A and PFAS-free concentrates by selecting the appropriate seal kit. The transition is a recommissioning, not a unit replacement.
- No electricity, no bladder tank. An advantage on jetties and offshore platforms classified under ATEX, where reducing the electrical envelope simplifies the safety case.
For mobile applications, the FireDos M9 monitor (10,000 to 40,000 l/min) paired with a portable FireDos proportioner gives operators a PFAS-ready response unit that deploys without retrofitting the host facility’s fixed system. Smaller incidents are handled by the M2 (500 to 2,500 l/min) and M4 (2,000 to 8,000 l/min).
PFAS-free concentrate families to evaluate
What SATU does, and what we don’t: Any foam concentrate selected for IMO 2026 service must be tested for proportioning-rate accuracy with your existing or new proportioner, and must satisfy the listing stack required by your underwriter and class society, before commissioning. SATU’s role is to scope and run that compatibility test — not to recommend a specific brand. The two PFAS-free product families most commonly evaluated for Thai marine and petrochemical service are BIOEX ECOPOL and the VERSAGARD family from Perimeter Solutions.
BIOEX ECOPOL family
BIOEX, headquartered in France, launched the first multipurpose Class A/B fluorine-free foam in 2002. The variants to evaluate include:
- ECOPOL Premium — alcohol-resistant fluorine-free foam: IMO MSC.1/Circ.1312 listed, MED Wheelmark certified for marine fire-protection use, EN 1568 Parts 3 and 4 (1A/1A on hydrocarbons and polar solvents), LASTFIRE, UL 162 and GESIP; suitable for hydrocarbons and polar solvents.
- ECOPOL F3HC — 3% Class B hydrocarbon foam, EN 1568-3 Class 1A, GreenScreen Certified Silver.
- ECOPOL A+ — ICAO Level B/C approved synthetic F3 for aviation and helideck protection.
- ECOPOL N — Newtonian fluorine-free formulation with viscosity close to AFFF, designed as a drop-in formulation that minimises proportioner re-tuning — verification still required.
VERSAGARD family by Perimeter Solutions
The VERSAGARD line is Perimeter Solutions’ next-generation AR fluorine-free flagship. The variant most commonly evaluated for Thai marine and tank-farm service is:
- VERSAGARD AS-100 3×3 — alcohol-resistant fluorine-free foam, 3% on hydrocarbons / 3% on polar solvents / 1% on Class A: UL 162 Listed, IMO MSC.1/Circ.1312 certified, EN 1568:2018 Parts 1–4 (1A/1A — 1A/1A on hydrocarbons and polar solvents, fresh and sea water), ICAO Level B, LASTFIRE Good/Good/Good across semi-aspirating, aspirating and system nozzles, GreenScreen Certified Silver.
A 12-month roadmap for Thai operators
Months 1 to 3: audit and gap analysis
Inventory every foam concentrate batch on site, including trailer and portable stocks. Cross-check against the supplier’s PFAS declaration and the 10 mg/kg threshold from MSC.532(107). Pull the original proportioner documentation and confirm whether the unit is UL Listed, FM Approved, and the design rate. Map every discharge device against its design density.
Months 4 to 6: select the replacement system
Choose the PFAS-free concentrate first, because it dictates the proportioner seal package. Confirm the new concentrate is third-party listed for the hazard class. Where the existing proportioner cannot be re-sealed, plan for a FireDos GEN III retrofit sized to the existing flow envelope.
Months 7 to 9: install and commission
Schedule the change-out around a planned shutdown. Drain and decontaminate the legacy AFFF lines, because residual PFOS in dead-leg piping will contaminate the new concentrate. Install the new proportioner, run flow and proportioning-rate tests, and document the result.
Months 10 to 12: ITM, training, class evidence
Run the first annual NFPA 25 ITM under the new system. Train the response crew on the new concentrate’s foam-expansion behaviour. Compile the documentation pack that Class, Flag State and corporate audit teams will ask to see.
What to ask your supplier before signing
If a vendor proposes a foam-only swap on a system older than 15 years, ask them to commit in writing to the post-retrofit proportioning rate. If they cannot, the proportioner is part of the scope. SATU works as the local FireDos service partner and provides the commissioning evidence required by Thai class surveyors and corporate EHS auditors. The same team delivers the supporting engineering, ITM and training services sequenced around your turnaround calendar.
FAQ
Does the IMO 2026 ban apply to my port firewater system, or only to ships?
MSC.532(107) and the SOLAS Chapter II-2 amendments apply to vessels and offshore installations. However, port firewater systems that supply ship-shore connections, and tank farms that connect to marine loading arms, are typically brought into compliance at the same time because the foam stocks are shared and the audit trail expects consistency.
Can I keep using my existing AR-AFFF until the stock runs out?
Existing stocks of AR-AFFF that contain PFOS above 10 mg/kg (0.001% by weight) cannot be retained on board after the first survey on or after 1 January 2026. They must be removed and disposed of as hazardous waste. PFAS-free or PFOS-free formulations that meet the threshold can be used through their service life subject to your Flag State.
Is FireDos compatible with PFAS-free concentrates from BIOEX or the VERSAGARD family?
FireDos GEN III FD1000 to FD20000 is foam-agnostic by design and supports AR-AFFF, AR-SFFF, FFF, Class A and PFAS-free concentrates — including BIOEX ECOPOL Premium, ECOPOL F3HC and VERSAGARD AS-100 3×3 — by configuring the appropriate seal package. The proportioning principle does not change with the concentrate, but the rate must still be measured and signed off after every concentrate change.
How long does a typical FireDos retrofit take on a Thai tank farm?
For a single-bund retrofit using an existing proportioner skid, four to six weeks from purchase order to commissioned system is realistic, assuming the foam concentrate is in country. For a full multi-bund tank farm or a jetty manifold, plan twelve to sixteen weeks.
Will the retrofit affect my insurance premium?
In our experience with Thai industrial insurers, demonstrating MSC.532(107) compliance and documented NFPA 25 ITM tends to be premium-neutral or favourable, because it removes a known regulatory risk. Confirm with your broker before treating it as a savings line item.
Plan your transition with SATU Innovative
The IMO 2026 PFOS foam ban is not a single event, it is a documentation-heavy retrofit programme that needs to be threaded through your existing turnaround calendar. SATU Innovative is the FireDos service partner in Thailand and has supported transitions for refinery, terminal and offshore clients. We provide the audit, the engineered retrofit, and the post-commissioning ITM documentation in one scope. Request a Quote and we will return a scoped proposal within five working days.
External References
- IMO MSC.532(107) and SOLAS Chapter II-2 amendments — imo.org — FSS Code and SOLAS fire safety
- DNV class guidance on the 1 January 2026 PFOS prohibition — DNV class news
- NFPA 11 (2024 edition) — nfpa.org/11
- BIOEX ECOPOL fluorine-free foam product line — bio-ex.com
- VERSAGARD AS-100 3×3 by Perimeter Solutions — perimeter-solutions.com
- FireDos GEN III stationary proportioners — firedos.com
Our Partners
SATU Innovative is the authorised Thailand service partner for the brands behind this guidance.
