Consultation feedback report: MO15 and MO49 amendments restricting PFOS in firefighting foams

Read about the results of consultation on proposed amendments to Marine Orders 15 and MO49 to introduce restrictions on the use of perfluorooctane sulfonic acid in firefighting foams.

Marine Order 15 (Construction – fire protection, fire detection and fire extinction) sets standards for the construction and installation of fire equipment on regulated Australian vessels (RAVs) and foreign vessels operating in Australian waters. It ensures these standards align with international fire safety rules for fire protection, detection, and extinguishing systems.

Marine Order 49 (High speed craft) sets out safety, certification and reporting requirements for high speed craft (HSC). It includes provisions related to fire systems and applies to HSC that are either RAVs or foreign vessels.

The proposed changes align with international fire safety standards and restrict the use of fire-extinguishing systems containing perfluorooctane sulfonic acid (PFOS).

Result

AMSA received one submission in favour of the proposed changes.

Key dates

  • Consultation period: 17 November 2025 to 18 December 2025
  • The amendments are scheduled to come into effect on 1 April 2026

Feedback report

Introduction

Marine Order 15 (MO15) (Construction – fire protection, fire detection and fire extinction) implements internationally consistent standards for the construction of fire equipment on vessels by giving effect to Chapter II-2 of the International Safety of Life at Sea Convention (SOLAS).

Marine Order 49 (MO49) (High speed craft) sets out the requirements for high-speed craft safety certificates, permits, marine incident reporting and notification of alterations to AMSA. It gives effect to the 1994 High Speed Craft (HSC) Code, the 2000 HSC Code and the Dynamically Supported Craft (DSC) Code.

Section 6 of Marine Order 25 (MO25) (Equipment - lifesaving) references the 2009 version of MO49 and will need to be amended to reference the 2015 version of MO49 to ensure vessels certified in accordance with the 2015 version are still considered compliant with international requirements.

The 107th session of the Maritime Safety Committee (MSC) adopted three resolutions restricting the use, storage and disposal of fire-extinguishing media containing PFOS which came into effect on 1 January 2026. These resolutions are:

  1. Resolution MSC.532(107) which amends SOLAS Chapter II-2 and will require amendments to MO15.
  2. Resolutions MSC.536(107) and MSC.537(107) which amends the 1994 and 2000 HSC Codes respectively and will require amendments to MO49.

This project combines the amendment of both MO15 and MO49 as a package, while incorporating the minor amendment to section 6 of MO25, giving effect to mandatory changes to SOLAS Chapter II-2 and the HSC Codes concerning PFOS restrictions and disposal management.

Consultation approach

The amendments to MO15 and MO49 place restrictions on the use and disposal of PFOS fire-extinguishing media. The amendments to MO15 will apply to regulated Australian vessels (RAVs) and foreign vessels to which SOLAS applies. The amendments to MO49 will apply to High-Speed Craft that are RAVs and foreign vessels.

The external consultation utilised AMSA’s targeted consultation lists for MO15 and MO49, which includes stakeholders with an interest in fire-fighting requirements under Chapter II-2 of SOLAS and High-speed Craft respectively. 

Public consultation

Overview

The public consultation on the proposed amendments took place between 17 November 2025 and 18 December 2025 for five weeks. A copy of the draft amendment instrument was placed on the AMSA website for public comment. Notification of the public consultation was also emailed to 129 recipients provided in the AMSA’s MO15 and 49 stakeholder lists, as well as those that have subscribed via our website. These stakeholders include port authorities, ship operating companies, seafarer representative organisations, classification societies, shipping industry peak bodies and interested government departments and agencies.

Key issues arising from feedback and AMSA's response

AMSA only received one submission from the public consultation process which was supportive of the PFOS restrictions. 

Download report 

Consultation feedback report Marine Orders 15 and 49 regarding PFOS PDF131.74 KB

Contact

If you require further information, please contact AMSA Connect.

Last updated: 11 March 2026