01 Feb Foams, PFOA & risk management strategies
It has become common place to read reports online and in printed media about “Toxic AFFF” or “Health Concerns associated with firefighting foam”, with many of these originating from the USA or Australia. Here andy hall of Hall Fire Safety Consultants reports that he is asked more and more frequently, by firefighters and facility owners, about the exposure risks, containment and disposal requirements when they use foam and asks, what is it in our firefighting foams that is creating these concerns?
The majority of Class B foams supplied and used globally over the last 50 years contain per- and polyfluoroalkyl substances (PFASs), also referred to as perfluorinated chemicals (PFCs) and in particular two compounds which the US EPA identified as being harmful to the environment, and from investigations on laboratory animals cause developmental and other adverse effects. These compounds are PFOS (Perfluorooctane Sulphate) and PFOA (Perfluorooctanoic Acid).
How long has this been known?
This is of course a question to be addressed to the environmental / health authorities but publicly we became aware of the concerns with PFOS in early 2000 when 3M Inc. the leading manufacturer of AFFF voluntarily withdrew from the firefighting foam market. The US EPA advised that PFOS has a PBT profile (Persistent, Bio-accumulative and Toxic) which led the chemical to be listed as a Substance of Very High Concern under Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and then
to be identified under the Stockholm Convention as a Persistent Organic Pollutant.
Other major manufacturers of foam agent used alternative fluorosurfactants including PFOA. Investigations by the US EPA concluded that PFOA, similar to PFOS, is also persistent in the environment, is found at low levels in the environment and in the blood of the general US population, and causes developmental and other adverse effects in laboratory animals.
Risk management strategies
Looking firstly at PFOA the chemical compound the US EPA took steps in co-operation with eight leading companies manufacturing per- and polyfluoroalkyl substances, to join in a global stewardship programme with the ultimate goal of eliminating these chemicals from emissions and products by the end of 2015. In 2017 the US EPA published the final progress report and confirmed that all the participating companies had achieved the stewardship programme goals.
Additionally, on January 21, 2015 the EPA proposed a significant new rule under the Toxic Substances Control Act to require manufacturers (and importers) of PFOA and PFOA-related chemicals to notify EPA before starting or resuming new uses of these chemicals in any products. This rule gives the EPA the opportunity to evaluate and if necessary prohibit or limit the activity.
In Europe, a three-year process relating to the restriction of the use of PFOA was finalised in 2017 with the issue on 13th June 2017 of Commission Regulation (EU) 2017/1000 amending Annex XVII to Regulation (EC) No. 1907/2006 of the European Parliament and the Council concerning the REACH as regards perfluorooctanoic acid (PFOA), its salts and PFOA-related substances. (PFOA-related substances are substances that, based on their molecular structure, are considered to have the potential to degrade or be transformed to PFOA)
Within this Regulation (Under Point 4) two different concentration limits are stated when considering when the chemical is used in the production of, or placed on the market in another substance, as a constituent; a mixture; or an article. These are 25 ppb of PFOA and its salts, and 1,000 ppb for one or a combination of PFOA-related substances. The regulation comes into effect for products placed on the market from 4th July 2020.
US and European strategies
The US EPA Stewardship Programme has led to the development of new fluorosurfactants with fewer than eight carbon atoms. The impact on the manufacturers of AFFF, FFFP etc. was the need to reformulate and relist their foam agents based on the so called C6 (short chain PFASs). The first of these solely C6 based AFFF’s appeared on the market around 5 years ago and now in 2018 all the major foam manufacturers are offering these short-chained based foam agents.
We have also seen renewed efforts by some foam manufacturers to formulate high performance Class B foam agents without fluorine chemicals leading to the launch of new FFF agents onto the market with claimed comparative fire performance to good AFFF’s.
Foam manufacturers and PFOAS
Interestingly the aforementioned EU Regulation allows the continued manufacture within the EU of foam concentrate
with longer chain PFCAs including PFOA until 4th July 2020. Both within the US and Europe it becomes almost impossible to formulate with these longer chains fluorosurfactants as the major manufacturers stopped manufacturing and supplying as part of the PFOA Stewardship Programme. Outside of the US and Europe foam manufacturers do not have to follow the regulations of the US or Europe.
What about foam users?
Within the EU the same regulation relating to the manufacture of firefighting foam agent until 4th July 2020 also applies to systems and foam agent that is supplied and in service by this date, meaning that as a user and you have a PFOA foam based system or PFOA based foam on your site available for firefighting then there is no restriction on the use of this agent for firefighting purposes or testing. The Regulation does state that if these foam agents are used for training purposes then emissions to the environment are minimised and effluents collected and safely disposed of.
Similarly, the US EPA has placed no restrictions on the use of PFOA based foam agents for firefighting use. It should however be noted that in November 2016 the US EPA established health advisories for PFOA and PFOS in drinking water. The health advisory level from the US EPA is 70 parts per trillion but at the time of writing a number of US States have set lower levels. This advisory has brought renewed focus to aviation and military training facilities where they have legacy issues due to repeated use of PFAS based foam agents, and also to POG and Chemical plants that have large hazards with an emergency response plan based on the use of PFAS foams.
Whilst even within the member states of the EU some countries or even states within countries have adopted more stringent restrictions on the use of these PFAS based foam perhaps the most comprehensive risk management programme related to the use
of firefighting foam agents is now in operation in Queensland, Australia. In July 2016, The Queensland Department of Environment and Heritage Protection introduced its Management of Firefighting Foam Policy, following nearly 3 years of investigations and consultations.
Within the Policy under section 6.2 Fluorinated firefighting foams the following regulations were put into place:
• Foams containing PFOS as well as its salts or any compound that degrades or converts to PFOA at a concentration greater than 10 ppm must be withdrawn from service as soon as possible.
• Foams that contain PFOA, PFOA precursor compounds or their higher homologues where the total organise fluorine content equivalent to PFOA and higher homologues exceeds 50 ppm must no longer be used and must be withdrawn from service as soon as practicable.
Additionally, the Policy addressed the use of the newer C6 based foams under section 6.2.4 Foams containing short-chain fluorotelomers:
• Foams containing short-chain fluorotelomers (C6 or shorter perfluorinated moieties) can be used if it is found to be the only viable option, after firefighting effectiveness, health and safety risks, environmental protection and property protection characteristics have all been appropriately considered, however, the following requirements must be met:
• The foam must be C6 purity compliant foam
• No releases directly to the environment (e.g. to unsealed ground, soakage pits, waterways or uncontrolled drains)
• All releases must be fully contained on site
• Containment measures such as bunds and ponds must be controlled, impervious and must not allow firewater, wastewater, runoff and other wastes to be released to the environment (e.g. to soils, groundwater, waterways, stormwater etc.)
• All firewater, wastewater, runoff and other wastes must be disposed of as regulated waste to a facility authorised to accept such wastes.
Firefighting in the Middle East
Remembering that this article is written from the position of regulations and legislation the only concern would be with PFOS as all of the Middle East States are signatories to the Stockholm Convention on Persistent Organic Pollutants.
Whilst there are now regional manufacturers and blenders for foam firefighting foam agents the majority of foam is still imported from US or Europe. As such the fluorinated foam agents should be formulated with C6 short-chain fluorotelomers. Accordingly, new supplies from 2016 coming into the region should have smaller (trace) amounts of PFOA.
Medium and high expansion foam systems generally do not contain PFASs, and there are a number of sites that have chosen to switch to Fluorine Free Class B foam agents
We are obviously into the realms of speculation and opinion now but the Queensland Policy is being studied within the other Australian States and no doubt is being discussed around the world. It is also worth noting that within the EU, there is currently a document being evaluated that addresses adoption of a different model for determination of substances of concern.
It is certainly a valid position to state that what I have now complies with the regulations and legislation in place. The fire industry however has recent history with Halon and with the life of foam agent expected to be 20 years or more if you are looking at new foam systems or replacement foam agent I would suggest you also need to evaluate how legislation might change during the lifetime of that foam!