Safety & Environmental Safeguards Affecting Machinery Spaces
From 1 January 2026, new and amended IMO requirements strengthen safety and environmental safeguards relevant to shipboard fuel handling, machinery-space fire protection and fire-extinguishing media. Key measures include enhanced controls on oil fuel flashpoint compliance under SOLAS Chapter II-2 and restrictions on PFOS-containing fire-extinguishing media. These requirements have practical implications for bunkering procedures, fuel-system safety, fire protection, equipment inspections and survey preparation.
Why These 2026 Safeguards Matter
Machinery spaces contain some of the vessel's most critical systems, including main and auxiliary engines, fuel systems, generators, pumps, boilers, compressors and associated electrical and mechanical equipment.
Safe fuel handling and effective fire protection are therefore fundamental to vessel safety. The 2026 requirements introduce additional compliance controls that shipowners, managers and operators need to incorporate into bunkering procedures, safety equipment inspections and survey preparation.
Two areas deserve particular attention: oil fuel flashpoint compliance before bunkering and the prohibition of PFOS-containing fire-extinguishing media.
Oil Fuel Flashpoint Requirements
Amendments to SOLAS Chapter II-2 Regulation 4 entered into force on 1 January 2026 to strengthen controls against the supply of oil fuel that does not comply with the SOLAS flashpoint requirement.
The applicable SOLAS requirement establishes a minimum flashpoint of 60°C for oil fuel used onboard, subject to the specific provisions and exceptions of the Convention.
Before bunkering, ships carrying oil fuel are required to be provided with a declaration signed and certified by the fuel oil supplier's representative confirming that the oil fuel supplied conforms with the applicable SOLAS flashpoint requirement and with the test method used to determine the flashpoint.
This SOLAS supplier declaration should be distinguished from the separate Bunker Delivery Note (BDN) requirements under MARPOL Annex VI. The BDN includes specified fuel information, including the applicable flashpoint information required under the MARPOL Annex VI documentation framework.
Bunker Delivery Note & Fuel Documentation
The Bunker Delivery Note (BDN) is an important part of demonstrating compliance with applicable MARPOL Annex VI fuel requirements and maintaining a traceable record of fuel supplied to the vessel.
BDN Fuel Information
The BDN contains prescribed information concerning the fuel delivered to the vessel. Under the applicable MARPOL Annex VI requirements, this includes fuel flashpoint information or, where permitted by the applicable requirement, the relevant statement concerning the measured flashpoint.
SOLAS Supplier Declaration
Before bunkering, the ship must receive the separate SOLAS declaration signed and certified by the fuel oil supplier's representative confirming conformity with the applicable SOLAS flashpoint requirement and the test method used to determine the flashpoint.
Why Fuel Flashpoint Is Critical to Machinery-Space Safety
Oil fuel with an unsafe flashpoint can increase the risk of ignition and fire onboard. Machinery spaces contain hot surfaces, exhaust components, electrical equipment and other potential ignition sources, making fuel safety particularly important.
The flashpoint requirement is therefore not simply a documentation exercise. It is part of the wider fire-safety system intended to reduce the probability of ignition during fuel storage, transfer and use.
Shipowners and managers should ensure that bunkering procedures clearly identify the required documentation and that relevant crew understand the importance of verifying bunker documentation before fuel transfer begins.
Contaminated or Off-Specification Fuel
Fuel quality problems can have consequences extending beyond regulatory compliance. Contaminated or unsuitable fuel can affect fuel pumps, injectors, filters, separators, engines and other components of the fuel system.
Poor fuel quality can contribute to operational problems such as filter blockage, abnormal combustion, equipment fouling and increased maintenance requirements. The consequences depend on the nature and severity of the fuel-quality problem.
Bunker documentation, representative fuel sampling and appropriate fuel-quality controls should therefore form part of the vessel's broader machinery reliability and risk-management programme.
PFOS Fire-Extinguishing Media Prohibition
A separate 2026 amendment to SOLAS Chapter II-2 introduces restrictions on fire-extinguishing media containing perfluorooctane sulfonic acid (PFOS).
The amendment prohibits the use or storage of extinguishing media containing PFOS. The measure is intended to protect persons onboard against exposure to dangerous substances used in fire fighting and to minimize the environmental impact of fire-extinguishing media considered detrimental to the environment.
When prohibited PFOS-containing media are removed from a vessel, the applicable SOLAS requirement provides that they are to be delivered to appropriate shore-based reception facilities.
When Does the PFOS Prohibition Apply?
Ships Constructed From 1 January 2026
For ships constructed on or after 1 January 2026, the use or storage of extinguishing media containing PFOS is prohibited under the applicable SOLAS requirements.
Existing Ships
Ships constructed before 1 January 2026 must comply with the PFOS prohibition no later than the date of the first survey on or after 1 January 2026, in accordance with the applicable SOLAS transitional requirement.
PFOS Compliance During Safety Equipment Surveys
Shipowners and managers should not wait until a scheduled survey to determine whether prohibited fire-extinguishing media remain onboard.
A practical compliance review should identify the type and location of fire-extinguishing media carried onboard and determine whether any equipment contains PFOS or another prohibited substance covered by the applicable requirements.
- Identify all fire-extinguishing media stored or carried onboard.
- Review manufacturer information and product documentation.
- Check fire-fighting systems and portable or fixed equipment as applicable.
- Identify legacy media that may contain PFOS.
- Arrange compliant replacement where required.
- Ensure prohibited media are removed through appropriate shore-based reception facilities.
- Maintain evidence of replacement and disposal.
- Include the review within the vessel's safety and maintenance programme.
Machinery-Space Fire Protection
Machinery spaces require a coordinated approach to fire prevention, detection and extinguishing. Fuel systems, lubricating oil systems, hot surfaces and electrical equipment can create significant fire risks if controls are inadequate.
Fire-extinguishing equipment must therefore remain suitable, available and compliant with applicable requirements. Replacement of prohibited fire-extinguishing media should be managed without compromising the vessel's required fire-fighting capability.
Any replacement should be compatible with the applicable fixed or portable fire-fighting arrangement and should be properly documented.
Survey Preparation for 2026 Compliance
Shipowners and managers can reduce the risk of survey findings by reviewing these requirements before the attending surveyor arrives.
- Review the vessel's bunkering procedures and documentation controls.
- Confirm that the required SOLAS supplier declaration is obtained before bunkering.
- Verify that the Bunker Delivery Note contains the applicable required fuel information.
- Confirm that the flashpoint information and applicable test method are properly documented.
- Review fuel-quality monitoring and machinery maintenance records.
- Identify all fire-extinguishing media carried onboard.
- Check whether any legacy fire-fighting media contain PFOS.
- Arrange replacement of prohibited media where required.
- Maintain appropriate records for replacement and shore-based disposal.
- Review outstanding class, statutory and safety-equipment findings.
- Ensure relevant crew are familiar with updated procedures.
Documentation That Should Be Available
Good documentation is essential when demonstrating compliance during statutory surveys, class attendance, inspections or audits.
Fuel Documentation
- Bunker Delivery Notes.
- SOLAS supplier flashpoint declaration.
- Applicable fuel-quality documentation.
- Fuel sampling and testing records.
- Bunkering procedures and checklists.
- Relevant certificates of quality and laboratory results where applicable.
Fire-Fighting Documentation
- Fire-fighting equipment inventory.
- Manufacturer information.
- Fire-extinguishing media specifications.
- PFOS identification or product information where applicable.
- Replacement records.
- Shore-based disposal or reception documentation where applicable.
Common Compliance Problems
Several practical problems can result in findings during inspections or surveys if compliance is not reviewed in advance.
- Missing or incomplete bunker documentation.
- Failure to obtain the required SOLAS supplier declaration before bunkering.
- Incomplete or inconsistent flashpoint information within fuel records.
- Insufficient control over fuel-quality documentation.
- Inadequate retention or traceability of bunker samples and test records.
- Legacy fire-extinguishing media remaining onboard.
- Unclear identification of the contents of fire-fighting equipment.
- Missing evidence of compliant replacement or disposal.
- Incomplete safety-equipment inventories.
- Outdated vessel procedures that do not reflect current requirements.
- Insufficient crew awareness of revised compliance procedures.
Role of the Independent Marine Surveyor
An independent marine surveyor can assist shipowners and managers by reviewing vessel documentation, identifying potential compliance gaps and assessing the physical condition of relevant machinery-space and fire-safety arrangements.
Technical review before a statutory or class survey can help identify issues relating to bunker documentation, fuel systems, fire-fighting equipment, maintenance records and other areas requiring corrective action.
Independent technical support does not replace the flag Administration, classification society or authorized statutory surveyor. Its purpose is to provide an additional technical assessment and improve survey readiness.
Technical Impact for Shipowners & Managers
Improved Bunkering Control
Stronger documentation controls help verify that supplied fuel meets the applicable SOLAS flashpoint requirements before bunkering operations commence.
Machinery Reliability
Effective fuel-quality control can reduce the risk of machinery problems associated with contaminated or unsuitable fuel.
Fire Safety Compliance
Identification and replacement of prohibited fire-extinguishing media helps maintain compliance with the applicable SOLAS fire-safety requirements.
Environmental Protection
Proper removal and shore-based handling of prohibited PFOS-containing media supports the environmental objectives of the amended fire-extinguishing requirements.
Frequently Asked Questions
What changed for oil fuel flashpoint requirements in 2026?
From 1 January 2026, amendments to SOLAS Chapter II-2 strengthen controls against supplying oil fuel that does not comply with the applicable 60°C flashpoint requirement. Before bunkering, ships carrying oil fuel must receive a declaration signed and certified by the fuel oil supplier's representative confirming that the fuel supplied conforms with the applicable SOLAS requirement and with the test method used to determine the flashpoint.
What is the SOLAS flashpoint requirement for oil fuel?
The applicable SOLAS requirement establishes a minimum flashpoint of 60°C for oil fuel used onboard, subject to the specific provisions and exceptions contained in the applicable SOLAS requirements.
What information should be confirmed before bunkering?
Before bunkering, the vessel should obtain the required supplier declaration confirming that the oil fuel supplied conforms with the applicable SOLAS flashpoint requirement and with the test method used to determine the flashpoint. The applicable Bunker Delivery Note should also contain the fuel information required under MARPOL Annex VI.
Does the SOLAS supplier declaration replace the Bunker Delivery Note?
No. The SOLAS supplier declaration and the Bunker Delivery Note serve different regulatory and documentary functions. The SOLAS amendment requires the supplier declaration before bunkering, while the BDN contains the prescribed fuel-delivery information required under the applicable MARPOL Annex VI requirements.
Why is fuel flashpoint important for machinery spaces?
Machinery spaces contain potential ignition sources including hot surfaces, exhaust components and electrical equipment. Oil fuel with an unsafe flashpoint can increase the risk of ignition and fire, making flashpoint compliance an important part of onboard fire prevention.
What is PFOS?
PFOS is perfluorooctane sulfonic acid, a substance that may be present in certain legacy fire-extinguishing media. The amended SOLAS requirements prohibit the use or storage of extinguishing media containing PFOS within the applicable scope.
When did the PFOS prohibition enter into force?
The relevant SOLAS amendments entered into force on 1 January 2026. Ships constructed on or after that date are subject to the prohibition, while ships constructed before 1 January 2026 must comply no later than the date of the first survey on or after 1 January 2026.
What should happen to PFOS-containing fire-extinguishing media?
Prohibited PFOS-containing extinguishing media should be removed from the vessel and delivered to appropriate shore-based reception facilities in accordance with the applicable SOLAS requirements and arrangements.
Does the PFOS requirement apply only to machinery spaces?
No. The prohibition concerns applicable fire-extinguishing media carried or stored onboard and is not limited exclusively to machinery spaces. The vessel's applicable fire-fighting arrangements should therefore be reviewed comprehensively.
Can fuel-quality problems affect machinery?
Yes. Contaminated or unsuitable fuel can contribute to problems involving filters, fuel pumps, injectors, separators, engines and other fuel-system components. The consequences depend on the type and severity of the fuel-quality problem.
Can PAMS assist with 2026 fuel and fire-safety compliance?
Yes. PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy support for vessel condition assessment, survey preparation, machinery-space inspections, bunker documentation review and fire-safety compliance preparation. PAMS does not replace the flag Administration, classification society or authorized statutory surveyor.
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Independent Marine Technical Consultancy
PAMS Pacific Admiralty Maritime Services is an independent marine technical consultancy based in Manila, Philippines, providing marine surveying, marine technical consultancy, offshore engineering consultancy, FPSO engineering support, marine audits, technical inspections and maritime compliance services.
PAMS provides independent technical support for shipowners, ship managers, operators, insurers and other maritime stakeholders, including vessel condition assessment, machinery and equipment inspections, survey preparation and regulatory compliance support.
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