“AFFF’s qualities as a fast and reliable suppression agent have literally been a lifesaver.” - National Fire Protection Association.

The advantages of using aqueous film-forming foams (AFFFs) containing per- and polyfluoroalkyl substances (PFAS) are well demonstrated, having been the standard tool in fighting flammable liquid fires (“class B” fires) since the 1960s. AFFF products containing PFAS are reliable and effective in the face of extreme and life-threatening circumstances. However, growing concerns over PFAS in the environment have forced a fresh look into the risk-reward calculation related to AFFF use.

When exploring alternatives to AFFF, fluorine-free foams (F3) represent an option, but their widespread adoption has been limited by the products’ historical inability to conclusively meet the U.S. Department of Defense’s (DoD’s) firefighting performance specifications, but that may be about to change.

Newly released DoD specifications fuel the transition from AFFF to F3

The DoD has been funding F3 product development since 2017, and the anticipated transition from AFFF to F3 received a substantial boost when the DoD released specifications for F3 on January 6, 2023. The specifications announcement occurs in accordance with the 2020 National Defense Reauthorization Act, which also requires the DoD to stop purchasing PFAS-containing foam by October 2023 and to replace all AFFF by October 2024.

Most major foam suppliers have F3 products, which have been on the market for the past several years.  The release of F3 specifications does not imply that current products can meet the specifications—but the specifications fulfill a necessary step toward large-scale AFFF-to-F3 transition. Furthermore, while the DoD is obligated to replace AFFF stocks within the next two years, private industry transitions remain discretionary. In the coming years, PFAS-containing AFFF might be phased out or banned, but the timing and path forward are not known at this time. 

Are F3 foams truly PFAS-free?

Given the ubiquitous presence of PFAS in society, creating any product that is truly ‘PFAS-free’ is often beyond the direct control of product manufacturers. In accordance with the DoD’s newly released specifications, F3 products must meet the following criteria:

• The product is tested via EPA Method 1633 and individual PFAS compounds are non-detect
• The total PFAS content is less than 1 part per billion (e.g., as measured via a total organic fluorine method)
• The manufacturer provides written certification that PFAS have not been intentionally added to the product

Tips and considerations for adopting F3

Transitioning from AFFF to F3 is not as simple as, say, changing the oil in your car. Facilities ready to explore adopting F3 may consider and prepare for several aspects, including:

• Equipment Compatibility: F3 products are not drop-in replacements for legacy or modern AFFF. For example, different foams have different viscosities, and may not be readily miscible. Existing equipment (e.g., nozzles, storage tanks) should be evaluated for compatibility with the new foam, and components should be replaced if compatibility is a concern. Taking steps to ensure equipment compatibility can be the difference between a system that performs as expected in an emergency and one that fails to meet expectations.  
• Ongoing Advancements: The DoD specifications release offers a step forward, but does not imply that the ideal F3 product is immediately available. Considerable research and development are underway to advance F3 performance.
• Equipment Contamination: A non-fluorinated F3 product can become contaminated by PFAS through contact with even a small amount of residual PFAS-containing foam. When replacing AFFF with F3, equipment should be carefully inspected to identify any components that have contacted AFFF.
• Performance Differences: F3’s performance and behavior during firefighting may be different from what personnel have come to expect through experiences using AFFF. Larger F3 quantities may be needed than was the case for AFFF. Facilities transitioning to F3 should plan sufficient time for product testing and personnel training.
• Communications: Facilities replacing AFFF with F3 should communicate the absence of PFAS-containing foam to potential mutual aid partners to avoid inadvertent deployment of PFAS-containing foam at a facility where foam has been replaced.
• AFFF Disposal: Replacing AFFF with F3 involves handling and disposing of AFFF, which should be approached with a level of engineering that prevents AFFF from being inadvertently released or disposed of in a manner that creates future liabilities. Incineration, landfilling, or deep-well injection may be considered; EPA has issued interim guidance, but none of these approaches have yet received final endorsement by the EPA for PFAS disposal. Incineration had been widely used for AFFF disposal, but in April 2022 the DoD issued a temporary moratorium on AFFF incineration, pending final EPA guidance on PFAS destruction/disposal. Incineration remains an option for private industry/non-DoD entities to consider for AFFF disposal. 
• AFFF Management: For facilities that have not transitioned to F3, an AFFF management plan is recommended. The management plan should consider containment, recovery, and disposal of AFFF in the event of emergency response deployment.

What’s next?

The DoD’s release of specifications is an intriguing development in the societal-level response to the PFAS challenge. However, based upon EPA and DoD guidance as well as overall industry response, it appears more remains to be done before wholesale replacement of PFAS-containing AFFF with F3 happens.

The near-term risks associated with firefighting must continue to be balanced against the long-term risks associated with PFAS in the environment. As the DoD’s mandatory transition away from AFFF progresses, we expect to see continuous F3 developments in performance, cost, and availability.

Questions?

Connect with us anytime! Whether you just need a question or two answered or are considering the move to F3, our professionals have the experience to support you. We will continue to monitor progress in this arena and provide updates in future articles.