Firefighting Foam and PFAS

Firefighting Foam and PFAS

Some fire stations may have
only Class A Foam; some fire
stations may have both 
Class A and Class B Foam.

The 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.
  1. 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 the fire, cools it, extinguishes the fire, and prevents the fire from relighting.  (Think fire triangle: oxygen, fuel, heat.)

How to Tell if Firefighting Foam Contains PFAS

It may not be easy to tell if the AFFF 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). You may also consult the GreenScreen for Safer Chemicals GreenScreen Certified™ Products | GreenScreen® For Safer Chemicals (greenscreenchemicals.org. 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:

    1. Current performance data is uncertain and/or lacking.

    2. 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.

    3. 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

To reduce the use of Class B AFFF and Reporting Use

Class B AFFF Best Practices Poster

As of July 2020, fire chiefs are required to:

  • Use only foam that doesn't contain intentionally added PFAS for training. .
  • Report the use of AFFF immediately after an incident to the Michigan Pollution Emergency  Alert System (PEAS) hotline at 800-292-4706.

In addition, fire chiefs and firefighter should:

  • Only use Class B AFFF for hydrocarbon fires, alcohol-based products, and aviation accidents to save lives or protect critical infrastructure. 
  • Continue to store Class B foam on-site until disposed of through the collection and disposal program (see below for more information).
  • See the Collection and Disposal Program, below, if interested in getting rid of Class B AFFF.

The Michigan Department of Licensing and Regulatory Affairs (LARA) created an informative poster with best practices for Class B foam, which include when it should be used and clean-up procedures.  This poster was distributed to all fire departments in the state of Michigan in 2019.

 

Collection and disposal program

2021 Class B AFFF Pickup and Disposal Program:

In December 2021 EGLE launched a second phase of the AFFF pickup and disposal program after learning there was additional Class B AFFF still in storage at fire stations that could be picked and properly disposed of.) AFFF pickup and disposal program due to learning that there is some Class B AFFF in fire stations that still needs to be picked up and properly disposed of.  If a fire chief has Class B AFFF they would like to have picked up, please contact Steve Noble, EGLE Materials Management Division, at NobleS4@Michigan.gov or 517-449-6153,

2019 - 2020 Class B AFFF Pickup 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 started on December 12, 2019, with a kick-off press conference and an initial pick-up at the Lansing Fire Department. Currently, US Ecology is contacting 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 would like to turn in for proper disposal. Read the January 3, 2020 collection and disposal letter.

  • 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.

Updated: January 12, 2022