3 Considerations When Replacing Firefighting Foams

For decades, aqueous film-forming foams (AFFFs) have been used by the aviation industry, chemical manufacturers, the military, and municipalities as a firefighting tool.  However, AFFFs contain per- and poly-fluoroalkyl substances (PFAS), which have shown potential for harm to human health and the environment.  As more information regarding the hazards of AFFFs becomes available, organizations are looking to replace legacy AFFFs with alternative foams, including short-chain “C6” AFFFs or even fluorine-free foams.  Specific to U.S. military operations, the National Defense Authorization Act (NDAA) calls for the reduced use of PFAS-containing foams by 2024.

AFFFs containing PFAS have been effective for emergency firefighting for decades, but the scrutiny and pressure to identify alternatives continues to intensify: 

  • As concerns over AFFFs increase, so do the number of lawsuits.  New York’s attorney general recently filed lawsuits against several chemical manufacturers for their role in spreading AFFFs throughout the market. Law suits have also been prepared, filed, or settled in several other states.  
  • AFFFs have also made headlines for failing to meet performance specifications, which require AFFF products to extinguish test fires within an acceptable timeframe.  The Federal Aviation Administration (FAA) recently issued an alert notifying FAA inspectors and staff of an AFFF product that does not meet standards and must be replaced in aircraft rescue and firefighting (ARFF) vehicles.

Given these developments, organizations now face the challenge of understanding and adopting appropriate replacement strategies.  If you are evaluating foam replacement options, consider these three tips to guide your efforts:

1.    Explore fluorine-free foams

While C6-based foams currently represent an available alternative to C8-based foams, their use comes with potential problems.  For instance, C6-based foams still contain trace concentrations of longer chain compounds, which fall above the Environmental Protection Agency’s (EPA’s) health advisory of 70 parts per trillion for combined concentrations of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS).  As such, you may consider moving to fluorine-free foams, which have already been adopted by major firefighting foam users such as airports, fire brigades, and refineries around the world.  Airport facilities outside the U.S. that have transitioned to fluorine-free foams have reported them to be virtually indistinguishable from AFFF foams operationally.

2.    Properly clean existing foam agent tanks and piping

Whether you are moving from C8-based foams to C6-based foams or from C6- or C8-based foams to fluorine-free foams, it is important to flush systems, tanks, and proportioning piping.  Delivery system components should also be verified for compatibility with the replacement foam.  All foams are not created equal (e.g. different viscosities), and equipment such as proportioners and nozzles may also require replacement.  Once you have properly flushed  components, remember to relabel equipment to reflect its new contents and add the correct safety datasheets.

3.    Measure environmental impact and performance

The primary goal of firefighting foam is that it effectively extinguishes flames, and an important objective of foam replacement programs involves reduced human health and environmental risks.  Incorporating measurable metrics for both factors in your replacement program will help balance performance demands with risk and can help you demonstrate benefits in a concrete manner.

Connect with us
Want to learn more?  Ask us your AFFF replacement program questions and join us at our upcoming PFAS webinar on February 13, 2020.

Mitch Olson, P.E.
Subject Matter Expert, Emerging Contaminants 
[email protected] 

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Andrew Pawlisz, DABT
Andrew Pawlisz, DABT
Senior Toxicologist, Tulsa, OK

Andrew is a board-certified toxicologist with over 20 years of experience in risk assessment and evaluation; hazard assessment; and regulatory compliance, including the legacy and reformed Toxic Substances Control Act (TSCA). Andrew specializes in finding practical solutions to regulatory and human health/environmental issues related to toxicants.
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