New PFAS restrictions from the EU, UK, and IMO are arriving in stages, directly impacting vessel operations, safety systems, and compliance planning across the marine and offshore sectors.
Here we’ll highlight the key regulatory changes and practical steps that matter most as deadlines approach. It's drawn from our comprehensive PFAS transition guide, available to download below.
Regulators across Europe and the UK are tightening controls on PFAS-containing firefighting foams due to their environmental persistence and contamination risks. The result is a phased transition away from legacy C8foams, with stricter rules around C6 AFFF use and increasing emphasis on validating fluorine-free alternatives (F3).
Two critical milestones are approaching:
With these deadlines on the horizon, operators should already be assessing their foam inventories and developing transition plans.
Offshore assets operate under conditions that extend well beyond those found on land or in sheltered waters. Extreme temperatures, wind exposure, and seawater induction all significantly influence foam performance. Recognising these operational realities, regulators have granted offshore installations an extended transition window until 2035.
This extended timeline allows operators to:
Performance remains non-negotiable. Environmental benefits must be achieved without compromising operational safety and reliability.
A proven, compliant solution for offshore and high-risk environments.
Environmentally preferable, though performance characteristics vary significantly.
Selecting the right approach depends on your specific operational environment and risk profile.
Most organisations begin their transition with these foundational actions:
1. Conduct a comprehensive foam inventory audit
Identify any remaining C8 foams, verify PFOS content levels, and test for cross-contamination.
2. Develop a replacement timeline
Coordinate foam changeouts with scheduled surveys, maintenance windows, and port calls to minimise operational disruption.
3. Maintain complete documentation
Record all testing results, disposal procedures, Certificates of Analysis, and Inventory of Hazardous Materials (IHM) updates.
4. Verify system compatibility before deployment
Test proportioning equipment, flow rates, and expansion characteristics before commissioning new foam products.
Offshore and marine platforms operate in high-risk, high-consequence environments with confined spaces, hydrocarbon processing, and limited emergency response options.
Key challenges include:
The extended 2035 transition period recognises these realities and allows operators to choose the most appropriate balance between performance, compliance, and environmental responsibility.
Maintain detailed records for inspections and audits, including:
Before re-commissioning:
While regulatory requirements are becoming more stringent, the fundamental objective remains unchanged: protecting people, assets, and the environment. The transition to PFAS-free operations is underway, but foam technology continues to evolve, particularly for demanding offshore applications. The extended timeline to 2035 provides valuable opportunity to evaluate emerging solutions without compromising safety
Prioritise vessels with approaching survey deadlines or regular EU port calls.
This article covers the essential elements, but our full guide provides significantly more depth:
The guide is designed specifically for operators superintendents, and HSEQ teams navigating this complex and rapidly evolving regulatory environment.
Download the complete guide to access all recommendations and ensure your foam transition strategy is fully prepared for upcoming deadlines.
Flare takes pride in being rigorously audited and certified by leading industry organisations.
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