As the fire service deals with per- and polyfluorinated chemicals better known as PFAS, you should realize all Aqueous Film-Forming Foams (AFFF) contaminate water resources.
This includes C6 products.
National Ground Water Association (NGWA) highlighted some issues in the United States: “Although Australia and European countries have used F3 alternatives for nearly a decade in certain sectors, adoption in the United States has been slowed by industry’s reliance on NFPA Standard 11 and UL 162, which address AFFF use for Class B fires…”
On cleaning apparatus, NGWA noted considerable lessons learned: “Equipment is often flushed with multiple water rinses to remove residue from the AFFF.
This water rinse approach has been shown to be ineffective, as long-chain PFAS can become bound to the inside surfaces of the equipment such that they will not dissolve into the water.
“While the water rinse may indicate the equipment is “clean,” the remaining surface-bound long[1]chain PFAS will readily dissolve into replacement foam products, which can result in gram per liter levels of legacy long-chain PFAS partitioning into the replacement C6-AFFF or F3.
This would effectively counter the effort to address environmental and regulatory drivers for making the transition.” In other words: “Water is a poor solvent for removing the surface[1]bound PFAS.” You will be producing more “batch mixed” AFFF.
Firefighting foams will continue to be used on fires.
AFFF are slowly being phased out in the United States including the Department of Defense and the FAA.
There is just one fluorine-free foam (F3) product on the Qualified Products List (QPL) currently that has passed the new land-based Military Specification (Mil-Spec).
Restrictions have been missing from AFFF for decades, but regulations are catching up due to risk management evaluations and legal pressures.
USEPA has worked with companies through numerous PFOA / PFOS voluntary stewardship reductions plans.
PFOA and PFOS are just two of 15,000 known chemicals in the PFAS class.
AFFF transitioned from C8 (long chain) to C6 (short chain) around 2015 because of on[1]going toxicity and persistence concerns.
The short chains were reported to be better, but they contain more PFAS than the previous AFFF concentrates and are still considered toxic as well as still persistent.
Used extensively during the last 60 years, AFFF contaminates ground and surface water which impacts drinking water.
PFAS spreads in water.
The chemicals will form long-ranging plumes in water or soil that can be determined by testing.
They are persistent and exceptionally difficult to break down because of the carbon-fluorine (C-F) bond.
Crucial information on firefighting foams had been unavailable to the fire service.
The Authority Having Jurisdiction (AHJ) must not be blocked from being given this critical information.
As Incident Commanders, they are the front-line risk managers.
State-level environmental offices may be listing foams on firefighting foam lists that are fluorine-free but still contain carcinogens.
Independent fire tested F3 products are available that do not contain carcinogens.
Fire departments have a choice to use foams with or without carcinogens.
Vanguard reported that: “Unfortunately, EPA has stated that PFAS are dangerous.
They do not dilute, degrade, or disappear, and they pose significant human health risk as they travel through our groundwater and soil.
“According to the EPA, PFAS have been linked to adverse human health effects including cancer, liver damage, thyroid disease and imbalance, immune disorders, cardiovascular concerns, and more.
Because PFAS is negatively persistent, it can move through drinking water, oil, and even concrete, and has contaminated drinking water in cities across the United States.” AFFF concentrates are found in:
• Airports
• Fire departments
• Fire academies
• Sprinkler systems
Fire training facilities have been contaminated throughout the US because of repeated training exercises.
Chemical manufacturers, petrochemical and oil refineries can be other sources of AFFF contamination.
Containers of AFFF products are being identified and continue to be removed by states with “take back” programs.
The Hazard Class 9 Department of Transportation (DOT) identification placard is used primarily in international transport.
This is a designation for miscellaneous hazardous materials until USEPA completes their regulatory process.
Unclassified hazardous materials placards are being used for PFAS transportation now.
By the end of 2024, it is predicted that USEPA will be finalizing PFAS into becoming subject to the Resource Conservation and Recovery Act’s (RCRA) list of “hazardous constituents.” No type of AFFF product should be poured onto the ground, sewer drains or water resources.
Once PFAS chemicals are in the water or soil, they become “a persistent problem for generations.” Underground toxic plumes are formed.
Testing water and soil samples can determine where AFFF has been used.
According to Jensen Hughes, Inc., fluorine-free foams are “consistent over a range of concentration levels, showed no difference at all from AFFF, and were still adequate across the board.” Fire departments in the US are continuing to transition to F3 foam products.
There are no regulations that require a fire department to use AFFF.
A few fire departments have recently found themselves facing state fines for using AFFF at incidents.
States are dealing with PFAS chemicals more quickly than EPA.
Apparatus clean-out may depend upon the AHJ.
Prepare for variations throughout the US.
Jackson Hole Airport has become one of the first US airports to change over to F3.
The airport is located within the Grand Teton National Park in Jackson, Wyoming.
After the US Department of Defense approved the first F3 product in September 2023, the airport “immediately initiated plans for its purchase.” The airport replaced AFFF with F3 foam in their existing fleet of aircraft rescue and firefighting vehicles (ARFF).
Delivery of two new ARFFs is anticipated in 2024.
Several major incidents in the US have revealed fire chiefs’ reluctance to use airports or other fire departments for mutual aid since their apparatus contain AFFF.
Fire chiefs do not want to contaminate their own community that they are charged with protecting.
The production of military[1]specification Aqueous Film Forming Foam (AFFF), a firefighting foam primarily used for extinguishing petroleum fires in military and aviation scenarios, has been undertaken by a range of companies since the 1970s.
Starting in that decade, 3M was among the first, when their manufacturing of AFFF ceased in 2009.
Across subsequent decades, brands like National Foam, Ansul, Angus, and Chemguard consistently produced AFFF, with some continuing into the 2020s.
The industry saw newer companies like Kidde and Buckeye start production in the 1990s and 2000s, while ICL Performance, Products Fire Service Plus and Amerex/Solberg entered the market in the 2010s.
It would be ideal to have your fire department’s F3 foam in place prior to a major emergency incident.
Airports are waiting to fill newly received ARFFs until they can get the new F3 foams for them.
PFAS chemicals are a health risk to firefighters and the public they serve.
Consider firefighters and public safety first.
Fire departments can stop exposures at the source by discontinuing AFFF use now.
