For shipowners, operators and suppliers of firefighting foam and foam systems, the transition to PFAS free firefighting foam is not only a product change, but a system and compliance decision.

Replacing the foam concentrate alone does not automatically result in a PFAS free firefighting system. Firefighting systems that have previously contained fluorinated foam will still have residual PFAS even after the old foam has been drained and replaced. Understanding this distinction is essential for making informed decisions and ensuring a verifiable and compliant transition.

Foam product versus system condition

PFAS free firefighting foam refers to the chemical composition of the foam concentrate supplied to the installation. A PFAS free system, however, refers to the condition of the entire firefighting installation, including tanks, piping, valves, pumps and sealing materials.

When fluorinated foam has been used in a system, fluorinated substances will remain within internal surfaces and components. As a result, a system filled with PFAS free foam can still contain PFAS residues if appropriate system preparation has not been carried out.

This distinction between foam product and system condition is addressed through what we refer to as FoamSafe Transition™, which focuses on system readiness beyond the foam concentrate itself.

Why PFAS residues remain in firefighting foam systems

PFAS substances are characterised by strong chemical stability and a high affinity for materials commonly used in firefighting systems.

Residual PFAS will remain because:

• fluorinated compounds adhere to internal tank and pipe surfaces
• residues can remain in valves, pumps, gaskets and hoses
• PFAS can be adsorbed into materials and released over time

Draining or replacing foam concentrate alone does not address these residuals. This is why a system focused approach, as applied through FoamSafe™, is required when transitioning to PFAS free foam.

Risks associated with assuming a PFAS free system

Assuming that a system is PFAS free based solely on the foam concentrate specification introduces technical and compliance risks.

Residual PFAS will:

• contaminate newly installed PFAS free foam
• result in non-conformities during sampling, inspections or audits
• complicate compliance with IMO, SOLAS and flag state requirements

create uncertainty regarding documentation and responsibility at handover

These risks affect both system owners and suppliers if system condition is not clearly addressed and documented.

Regulatory and compliance perspective

Regulatory frameworks increasingly focus on the actual condition and suitability of the firefighting system, not only the declared properties of the foam concentrate.

Under IMO and SOLAS related requirements entering into force from 1 January 2026, subject to flag state implementation, system suitability for PFAS free foam must be demonstrable. This includes consideration of residual fluorinated substances remaining in existing installations.

Within this context, FoamSafe Transition™ provides a clear framework for addressing system condition separately from foam supply, supporting compliance without shifting responsibility away from the system owner.

The role of system cleaning

System cleaning addresses the gap between a PFAS free foam product and a PFAS free system.

Through FoamSafe™, system preparation aims to:

• remove residual fluorinated substances from tanks and piping
• prevent contamination of PFAS free foam after installation
• support documented compliance with applicable regulations
• clarify responsibility and reduce ambiguity between parties

Without addressing system condition, the transition to PFAS free foam will be incomplete and difficult to verify.

Key takeaway for owners and suppliers

Replacing firefighting foam with a PFAS free product is an important step, but it does not by itself guarantee a PFAS free system.

A compliant and verifiable transition requires a clear understanding of system condition, residual contamination and responsibility boundaries. This is the basis of FoamSafe Transition™, with FoamSafe™ representing the applied, system focused approach used to support that transition.