Firefighting Foam and PFAS

Firefighting Foam and PFAS

There are two major classes of firefighting foam:

1. Class A Foam: Used to extinguish Class A materials, such as wood, paper, and brush (wildland), is widely used by many fire departments for structural firefighting using compressed air foam systems.

2. Class B Foam (also called AFFF): Used to extinguish Class B materials, which include gasoline, oil, and jet fuel.

Aqueous film forming foam (AFFF, or alcohol resistant AR-AFFF) is a highly effective foam used for fighting high-hazard flammable liquid fires.  AFFF is usually created by combining foaming agents with fluorinated surfactants.  Per- and polyfluoroalkyl substances (PFAS) are the active ingredient in these fluorinated surfactants.  When mixed with water and discharged, the foam forms an aqueous film that quickly cuts off the oxygen to a flame, extinguishes the fire, and stops the fire from relighting.

How to Tell if Firefighting Foam Contains PFAS

It may not be easy to tell if the foam you have contains PFAS.  These chemicals are not required to be reported on any safety data sheets (SDS), as they currently are not considered a hazardous substance.  PFAS may not be listed under any active ingredients list, either.  A good indicator that the foam contains PFAS is if it mentions fluorosurfactant, fluoroprotein, C6, or the use of “fluoro”, however, not all fluorinated surfactants are made of PFAS.  The best thing to do is to note the brand and manufacturer of the foam and contact the manufacturer in writing to see if PFAS is used in its production and ask for the SDS.  Be sure to be clear that you mean the entire family of PFAS, not just the single compound PFOS, and be sure to review the SDS.

Following is an example of PFAS language from a Safety Data Sheet:

Product Name: Buckeye 3% Mil Spec AFFF

In Section I, Chemical Product and Company Identification, we find AFFF Concentrate, Aqueous Film Forming Foam.  This is our first clue that the product may contain PFAS.

In Section III, Composition/Information on Ingredients, we find “Proprietary mixture of Fluorosurfactants (bolded to identify key words) and hydrocarbon surfactants”.  This AFFF contains PFAS. 

Further, note the below statement does not mean it does not contain PFAS.  It means the product was manufactured with PFAS that did not contain PFOS. Also note, that PFAS is not mentioned anywhere else in the SDS.

Flourine-free AFFF

Now that we know what to look for, you can learn more information on PFAS-free material from the Interstate Chemicals Clearinghouse, including a List of Known PFAS-free Foam. (this list is accurate as of April 2019) Please note, the State of Michigan does not endorse or recommend any specific product.

Also, be aware that performance and testing of the fluorine-free AFFF is still going on. Below are the current findings. 

What we Know and Don't Know About Flourine-Free AFFF

From the review of firefighting foam performance standards, current and upcoming regulations, identification of fluorine-free foams, other researchers working in this area, and literature, the following conclusions and actions have been identified:

1. Three main information gaps need to be filled to characterize fluorine-free foams in order to promote them as safer alternatives to fluorinated foams:
   • Current performance data is uncertain and/or lacking.
   • The makeup of foams is incomplete as many ingredients are protected as confidential business information.  Many researchers and those in the firefighting foam industries have raised a concern about whether foams are truly fluorine-free or not.
   • The ecotoxicity and impacts on human health of most fluorine-free foams and their ingredients have not been characterized or assessed.
2. Organizations are developing fluorine-free foams, characterizing them, and performing alternatives assessments.  Washington is the first U.S. state to ban the sale of fluorinated foams.
3. There is no regulation preventing the use of fluorine-free foams by non-military users, including firefighting training centers, chemical manufacturers, oil refineries, and others. 

For additional information on AFFF please contact the Environment, Great Lakes and Energy (EGLE) Department’s Environmental Assistance Center at 1-800-662-9278

The Fire Station Survey

Class B foam is the most effective way to combat Class B fires and save human lives, but it can contain PFAS. PFAS is the entire class of per- and polyfluoroalkyl substances, which contains thousands of individual PFAS chemicals. To find out which fire stations in Michigan currently have or have had Class B foam, and therefore the potential to use or have used foam containing PFAS, the Fire Marshal conducted a survey of all Michigan fire stations in 2018. 

A total of 1,035 fire departments received the survey in March 2018. The survey is closed as of October 1, 2020. The key questions the survey asked were:

• Whether the fire department has Class B foam and if so, how many gallons.
• When the last time the fire department trained with Class B foam.
• If the fire department used the Class B foam for an emergency within the last 5 years.

Results

Approximately 803 (or 77%) of the fire departments surveyed responded as of September 30, 2020, and of these, 383 (48%) reported having Class B foam.  The total amount of Class B foam reported was 40,812 gallons.

The survey results were used to develop a statewide solution for collecting and disposing of most of the Class B foam so it no longer poses a threat to the environment. Not all Class B foam will be collected and disposed because:

• Some fire stations will need to continue to have some Class B foam on hand if they are likely at some point to have to extinguish a Class B fire to save human life.
• Currently, there are limited PFAS-free Class B foams available.  Fire departments looking for replacement foam that is PFAS-free should thoroughly research the alternatives prior to purchasing.

COLLECTION AND DISPOSAL PROGRAM

In November 2019, US Ecology was awarded a contract from the Department of Environment, Great Lakes and Energy to collect and properly dispose of Class B AFFF and AR-AFFF containing PFAS. The collection and disposal efforts officially started on December 12, 2019, with a kick-off press conference and an initial pick-up at the Lansing Fire Department. US Ecology contacted the fire departments that participated in the Bureau of Fire Services’ Class B AFFF survey to coordinate a date and time to collect any Class B AFFF containing PFAS that fire departments wanted to turn in for proper disposal. Read the January 3, 2020 collection and disposal letter.

US Ecology’s contract was based on the estimated 37,000 gallons of Class B AFFF reported out in the AFFF survey.  When the collection program ended on September 30, 2020, US Ecology had picked up 51,404 gallons of AFFF.

PFAS Fire Fighting Foam: Treatment of Contaminated Sites and Foam Disposal (recorded June 2, 2020, 64 min)

This is a recording of a webinar held to discuss the AFFF pickup and disposal program and how communities could participate in the program.  The webinar was intended for municipal and regional government officials, wastewater managers and directors, landfill owners and operators; operations and maintenance personnel, scientists, product and service providers; project managers and engineers, environmental consultants, water advocacy organizations, environmental and community groups, and anyone interested in PFAS impacts in the Great Lakes region.

WHAT DO WE DO MOVING FORWARD?

Fire departments have been asked to:

• Use only Class A foam unless Class B foam is needed to protect human life or critical infrastructure.
• Train only with Class A foams.
• Continue to store Class B foam on-site until disposed of through the collection and disposal program (see below for more information).
• The Michigan Department of Licensing and Regulatory Affairs (LARA) is working to educate fire departments that Class B foam should not be used unless necessary to save lives or protect critical infrastructure. LARA has put together an informative poster with best practices for Class B foam, which include when it should be used and clean-up procedures.
  • Download the Class B AFFF Best Practices poster. 
  • This new poster will be displayed in all fire departments across the state, reminding firefighters to refrain from training with Class B AFFF Foam. State Fire Marshal Kevin Sehlmeyer also reminds firefighters to only use Class B AFFF Foam for specific types of fires and to call the PEAS hotline if Class B AFFF Foam is used.
• Report releases of Class B foam to the Michigan Pollution Emergency Alert System (PEAS) hotline at 800-292-4706.

Changes to Michigan Pollution Emergency Alert System (PEAS) Calls

The Michigan PFAS Action Response Team - Fire Station Workgroup also worked with the Michigan Department of Environment, Great Lakes, and Energy (EGLE) to change reporting the use of Class B foam to the Michigan Pollution Emergency Alerting System (PEAS) at 800-292-4706. Callers to the toll-free PEAS line are asked if Class B foam was used at the fire (or explosion or spill) to determine if response actions are needed.

Updated: September 30, 2020