‘Forever chemicals’: What firefighters need to know about AFFF and PFAS

For decades, firefighters have used aqueous film-forming foam (AFFF) to help extinguish difficult-to-suppress fires, particularly Class B fires involving petroleum products or other flammable liquids. And while AFFF formulations have proven to be extremely effective in suppressing those fires, we are now learning that the use of AFFF has had serious unintended consequences for both the firefighters who used it and the communities they protect.

PFAS PROBLEMS

Some AFFF formulations contains per- and polyfluoroalkyl substances (PFAS), a class of chemicals that have been widely used for decades in a variety of applications beyond firefighting foam, including nonstick cookware, stain-resistant carpets and fabrics; coatings on some food packaging; and a variety of industrial applications.

We are all exposed to PFAS, and it can be found in the blood of virtually every American. According to the Environment Working Group (EWG), the presence of PFAS in our food, water, and consumer products has been linked to health hazards, including cancer, reproductive and developmental harms and reduced the effectiveness of vaccines.

Certain PFAS chemicals are no longer manufactured in the United States as a result of phase-outs. However, PFAS are extremely stable and thus do not break down in the environment and can accumulate over time. One serious concern regarding PFAS for the fire service is their potential for contamination of groundwater sources when AFFF leaches into the soil.

AFFF AND ITS ENVIRONMENTAL IMPACT

The primary concern centers around the potential negative impact on the environment from the discharge of AFFF, with the primary issues being the toxicity, biodegradability, persistence, treatability in wastewater treatment plants, and nutrient loading of soils. All of these are cause for concern when foam solutions reach natural or domestic water systems.

When AFFF is repeatedly used in one location over a long period of time (e.g., fire training facilities), the PFAS can migrate from the foam into soil and then into groundwater. The amount of PFAS that enters the groundwater depends on the type and amount of AFFF used, where it was used, the type of soil and other factors. If private wells or public well fields are located nearby, they could be affected by PFAS.

FIREFIGHTERS FACE A HIGHER RISK

The International Pollutants Elimination Network (IPEN) is a global network of public interest organizations working to improve chemical policies and increase public awareness about hazardous chemicals to ensure that hazardous substances are no longer produced, used or disposed of in ways that harm human health and the environment.

In an October 2019 white paper, an IPEN expert panel shared: “Unequivocal evidence from recent studies [show] that firefighters using aqueous film-forming foams (AFFF) have unacceptably elevated blood levels of both PFHxS [perfluorohexane sulfonate] and PFOS.” The experts also noted that firefighters have a higher risk of exposures to PFHxS and other PFAS from several sources:

• Using firefighting foam [AFFF] for fire suppression operations and training;
• Contact with contaminated PPE;
• Handling equipment contaminated with AFFF;
• Managing PFAS foam wastes; and
• Occupation of contaminated fire stations.

“Our firefighters and first responders are already asked to put themselves in harm’s way virtually every day,” said David Andrews, Ph.D., a senior scientist at the EWG. “Forcing them to use firefighting foams containing dangerous chemicals, when there are alternatives that work, puts their long-term health at an unacceptable risk.”

A CASE STUDY

In March 2018, Michigan’s State Fire Marshal conducted a survey to assess which fire departments in Michigan currently had or have had Class B foam, and therefore the potential to use or have used foam containing PFAS. The survey was distributed to 1,035 fire departments and sought responses to these three questions:

1. Did the fire department currently have Class B foam, and if so, how many gallons?
2. When was the last time the fire department trained with Class B foam?
3. Had the fire department used the Class B foam for an emergency within the last 5 years?

Of the 803 participating departments, 383 (48%) reported having Class B foam on hand. The total amount of Class B foam reported was 40,812 gallons.

The survey results were then used by the Michigan Department of the Environment, Great Lakes, and Energy (DEGLE) to develop a statewide solution for collecting and disposing of most of the Class B foam so it would no longer pose a threat to firefighters or the environment. However, DEGLE determined that not all Class B foam would be collected and disposed of because some fire stations would need to continue to have Class B foam on hand to extinguish a Class B fire. Further, there were limited PFAS-free Class B foams available. Fire departments looking for replacement foam that is PFAS-free were directed to thoroughly research the alternatives prior to purchasing PFAS-free foam.

DEGLE next established a PFAS Action Response Team to coordinate the state’s efforts to remove AFFF from fire departments. In November 2019, a private sector vendor, US Ecology, was awarded a contract to collect and properly dispose of AFFF and AR-AFFF (alcohol-resistant AFFF) containing PFAS.

Image/Michigan Department of Licensing and Regulatory Affairs

That collection and disposal effort kicked off in early December 2019 with the first pick-up taking place at the Lansing Fire Department. US Ecology used the information from the Fire Marshal’s AFFF survey to establish dates and times for collection of AFFF and AR-AFFF from those fire department’s that had expressed the desire to turn in their foam for proper disposal. When the foam collection program ended on Sept. 30, 2020, US Ecology reported having picked up a total of 51,404 gallons of AFFF and AR-AFFF.

Moving forward, fire departments in Michigan have been asked to:

• Use only Class A foam unless Class B foam is needed to protect human life or critical infrastructure;
• Train only using Class A foams; and
• Continue to store Class B foam on-site until disposed of through the collection and disposal program.

The Michigan Department of Licensing and Regulatory Affairs (LARA) has since been working on an education program around Class B foam use. LARA created a poster with best practices for Class B foam, which include when it should be used, plus clean-up procedures (See Figure 1 ).

CURRENT STATE OF REGULATION OF AFFF

According to the EWG, there are now safer and equally effective alternatives to AFFF, and many states are prohibiting the use of PFAS-based foams, such as AFFF and AR-AFFF. Further, the National Defense Authorization Act now directs all Department of Defense fire departments to stop using AFFF and AR-AFFF by 2024. And last year, Congress directed federal work safety experts to certify PFAS-free firefighting gear as well.

Vicki Quint is a firefighter advocate working to educate the fire service about PFAS chemicals because currently there are no regulations preventing non-military fire departments from using fluorine-free firefighting foams (i.e., non-AFFF or non-AR-AFFF foams). The group’s Foam Exposure Committee provides the following do’s and don’ts for fire departments that still have AFFF or AR-AFFF:

• Don’t dump AFFF into a storm drain, the sewer or landfills;
• Don’t sell or give away fluorinated AFFF or AR-AFFF to other fire departments;
• Don’t send AFFF to a training site or a fire academy to use;
• Do evaluate your fire department’s standard operating procedure (SOP) for the use of firefighting foams; and
• Do store AFFF and AR-ARFF foams safely until you can receive direction from your state Department of Environmental Quality (DEQ), Department of Environmental Protection (DEP), Department of Natural Resources (DNR) or State Fire Marshal.

These products must be stored safely for pick-up and proper disposal. Protect your firefighters, your fire department and the community.

FOAM DISCHARGES

It will be some time before AFFF and AR-AFFF are no longer in use by fire departments, so it’s incumbent upon firefighters to be educated about how to deal with AFFF or AR-AFFF discharges. Such discharges can include, but are not limited to, the following scenarios:

• Manual firefighting or fuel-blanketing operations;
• Training exercises where foam is being used in the scenarios;
• Foam equipment system and vehicle tests; or
• Fixed fire protection system releases.

Locations where one or more of these events would most likely occur include aircraft facilities and firefighter training facilities. Special hazard facilities, such as flammable/hazardous material warehouses, bulk flammable liquid storage facilities and hazardous waste storage facilities also make the list.

Fire departments should consider any discharge of AFFF or AR-AFFF as a separate hazardous materials incident (beyond the foam itself, the foam is likely contaminated with the fuel or fuels involved in the fire). Firefighters should employ the same defensive hazmat tactics (e.g., damming, diking, and diversion) to get the foam/water solution to an area suitable for containment until it can be removed by a licensed hazmat cleanup contractor.

TRAINING WITH FOAM

There are specially designed training foams available that simulate AFFF during live training, but do not contain PFAS. These training foams are normally biodegradable and have minimal environmental impact; they can also be safely sent to the local wastewater treatment plant for processing.

Fire instructors and firefighters should be aware that the absence of fluorosurfactants (a subgroup of PFAS) in training foam means that those foams have a reduced burn-back resistance. For example, the training foam will provide an initial vapor barrier in a flammable liquids fire resulting in extinguishment, but that foam blanket will quickly break down. (That’s one “upside” from an instructor’s point of view, as it means you can conduct more training scenarios because you and your students are not waiting for the training simulator to become burn ready again.)

Training exercises, particularly those using real finished foam (foam that’s generated by the proper percentage of foam concentrate, water and air), should include provisions for the collection of spent foam. At a minimum, fire training facilities should have the ability to collect the foam solution used in training scenarios for discharge to a wastewater treatment facility. Further, prior to the use of training foam, the fire department should notify the local wastewater treatment facility and gain permission for the agent to be released at a prescribed rate.

PROTECT YOUR PEOPLE

The firefighting foam landscape has changed dramatically in the last 10 years. It’s imperative that fire departments inform and educate their personnel regarding those changes – and that they revise training and operational SOGs to reflect these changes to help safeguard the health and wellness and safety for their personnel.