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Firefighters on the PFAS front

Marinette Creek, Marinette, Wisconsin in October 2020, showing foam run-off from the Tyco fire training facility. (Image copyright: Foam Exposure Committee) — Image copyright: Foam Exposure Committee

Firefighters have been on the front lines of firefighting foams containing PFAS chemicals for decades. Yet, they have not been informed and could still be unaware of PFAS toxicity issues.

When the Foam Exposure Committee (FEC) began testing for total fluorine in firefighting foam samples, they did so with a focus on firefighters’ personal direct exposures.

The Leader’s Edge reported in Jan/Feb 2020: ‘PFAS is a true cause for concern. We can expect more regulations at the federal and state levels, lower ‘margin of protection’ threshold levels, and an uptick in litigation. This isn’t going away any time soon.’¹

‘Led by Washington State in 2018, other states are restricting use of AFFF for many non-federally mandated firefighting entities, banning its use in all training exercises, and even requiring disclosure of PFAS in firefighting gear.’²

There are currently other actions evolving in the United States which are driving upcoming changes in the use of firefighting foams including health concerns. State level and national governmental entities are involved in these projected modifications.

Department of Defense

The Department of Defense (DoD) Military Specification (MilSpec) for Aqueous Film-Forming Foam (AFFF) defines the AFFF which is why it receives attention from the public fire service.

‘Safer effective alternatives to PFAS foams are in use all around the world. The US Department of Defense should use them to protect the health of communities and firefighters.’³ The fire chief of Heathrow Airport reported: ‘Since purchasing our fluorine-free foam, we have used it on two separate aircraft fires (an A321 and a 787) and it worked perfectly.’⁴

There are two aspects of the DoD MilSpec for Aqueous Film Forming Foam (AFFF): the specifications setting forth the minimum testing requirements and then the actual product that is produced to the MilSpec.

After the PFAS Task Force was formed by the DoD in July 2019, DoD began working with other federal agencies to remove AFFF while trying to maintain transparency. In 2018, Pentagon officials had released a listing for the first time of 126 military installations where PFAS was found in higher than recommended levels.⁵ DoD is progressing through the cleanup process, conducting an assessment of PFAS use or potential release which increased from 401 to 651 locations as of the end of 2019.

The DoD PFAS Task Force Progress Report dated 13 March 2020 states that fire apparatus needs to be addressed:

‘In planning for an AFFF replacement, as required in the FY 2020 National Defense Authorization Act (NDAA), the Congressional Budget Office (CBO) estimated that it would cost DoD $35,000 per vehicle to retrofit to a new firefighting foam technology. However, DoD has learned from previous foam transitions that fully removing foams containing PFOS or PFOA from current systems will likely require replacement of almost every component of Aircraft Rescue and Firefighting (ARFF) vehicles. Therefore, DoD estimates the cost of retrofit efforts at nearly $200,000 per vehicle, which adds $600 million to the CBO estimate and is at least 30 percent of the cost to replace an ARFF vehicle. Based on DoD’s estimate, ARFF vehicle replacements may be required to meet the NDAA requirement. Replacing DoD’s fleet of approximately 3,000 ARFF vehicles would cost $4 to $6 billion and may take over 18 years at current commercial production rates, assuming DoD could acquire 50 percent of current commercial production. However, commercial airports in the United States employ a fleet of ARFF vehicles more than twice the size of DoD’s, which may impact availability and replacement timelines. DoD is currently researching methods to fully remove foams containing PFOS or PFOA from current systems without having to replace ARFF vehicles.’⁶

The AFFF MilSpec has had minimal amendment updates in over 58 years. Now, the military is acknowledging that the ‘bottom line is that the MilSpec may need to change.’⁷Although the military is calling for a ‘drop-in replacement’, that appears highly unlikely due to major changes in aircraft fluorine-free firefighting foams and fuels covering decades of technological progress.

The DoD’s goal is to transition to a fluorine-free AFFF alternative.⁸

The DoD PFAS Task Force is also evaluating PFAS issues outside of the United States. The potential necessity for two separate MilSpecs for firefighting foam is being considered: one form for installations and another one for ships. More than just fire apparatus tanks will need to be decontaminated. Any equipment that has come into contact with PFAS will require decontamination or replacement, i.e., hoses, nozzles, etc.

The New York Times reported that DoD is seeking permission to increase the acceptable threshold for PFAS contamination in groundwater and to change the way contamination levels are calculated by having separate limits for PFOS and PFOA.⁹

Horse-drawn fire engine (Foam Exposure Committee) — The US AFFF MilSpec has only been updated twice in 58+ years of use. The product has not kept pace with technological changes in aircraft or fuels but the DoD is wanting to have a drop in product available. Two firefighting foam products were dropped from the Qualified Product Listing (QPL) listing in April 2020. (Foam Exposure Committee)

FAA

In 2018, the US Congress passed legislation directing the Federal Aviation Administration (FAA) to change its requirement that airports must use fluorinated foams:

‘The provision is included in a larger legislative package – the FAA Reauthorization Act of 2018 (HR 302) – that covers a range of reforms to the FAA, as well as federal disaster programs. It directs the FAA to no longer require the use of fluorinated chemicals to meet federal performance standards for extinguishing agents used in airports nationwide.’¹⁰

This legislation requires the FAA to make the change within three years of the bill’s signing date which occurred on 5 October 2018. This was ordered to be done in accordance with the EPA and the latest version of NFPA 403, Standard for Aircraft Rescue and Fire-Fighting Services at Airports.

‘All 27 major Australian airports have transitioned to fluorine-free foams, as have many major international airports, including London Heathrow and Gatwick, Paris-Charles De Gaulle and Dubai. Fluorine-free foams are used by oil and chemical manufacturers, including BP, ExxonMobil, Statoil, BASF, AkzoNobel, Pfizer and Lilly.’¹¹

The National Academy of Sciences had conducted a survey of 167 North American airports between 2015 and 2016. The survey reported: ‘Less than 7 percent of the airports treated AFFF during training like hazardous waste…’¹² This can be an issue.

More on US AFFF activity

The State of Washington banned and will penalize per- and poly-fluoroalkyl substances (PFAS) in Class B firefighting foam designed for flammable liquid fires and firefighting personal protective equipment to be worn by firefighting personnel intended for use in fire and rescue activities. There are limited exceptions. This law went into effect on 1 July 2018.¹³

In May 2018, Massachusetts announced a take-back program to assist fire departments in the proper disposal of legacy firefighting foams that could impact water resources.¹⁴ Any AFFF manufactured prior to 2003 was eligible. Fluorinated firefighting foams are considered highly toxic because they contain PFAS chemicals with foams produced prior to 2003 being considered the most toxic.

The State of California has announced a PFAS ban in AFFF as of 2021 that will affect 20% of the US.

‘Foam is generally intended for use on Class B fires only, although AFFF is an excellent Class A wetting agent.’¹⁵ Traditionally, AFFF products have been used across the different foam classes as regulated by the National Fire Protection Association, i.e. 1%. In the US 75% of all AFFF concentrates are used by the military, while the remaining 25% are used by municipal airports, refineries, fuel tank farms, and other industries.¹⁶

Complete Safety Data Sheet (SDS) information on fluorinated foams has been withheld because of ‘proprietary concerns.’ But products are also expected to be compatible as well as adhere to specific Military Specifications. The US Fire Administration is advocating to replace older AFFF stocks with fluorine-free foam solutions.¹⁷ Fire departments tend to keep old stock indefinitely.

Fire departments have utilized AFFF for training purposes in order to use it up. This increases the risk of fire stations and fire-training facilities as sources of local PFAS contamination because of repeated foam use.

Michigan has been very pro-active in testing for PFAS. The state posted an article on ‘How to Tell if Firefighting Foams Contain PFAS’ which showed examples of how to tell if a firefighting foam contains PFAS.¹⁸But, checking a label can still be a guessing game. Nothing on the labelling depends on the SDS – but one of the conclusions the FEC arrived at is that if it is labeled as a Class B foam, it contains PFAS (C6 and/orC8). If it is labeled as Class A, it likely does not but this is less absolute. There are some other cases where PFAS were observed and the source is less clear. A better solution would be to test a foam product for total PFAS to know if it is really fluorine-free.

Health impacts

‘Firefighters who use these products have been shown to have greater exposures as compared to the general population. Dobraca et al. (2015) compared perfluoroalkyl serum levels of a group of firefighters in California to an adult population from the NHANES survey.’¹⁹ In a small-scale study of 37 firefighters participating in the C8 Health Project, significantly (adjusted for age, water district, household income and smoking) higher levels of PFOA and PFHxS were found in the firefighters compared to 5,373 male participants with other jobs (Jin, et al. 2011).

‘Human exposure to PFAS can be via ingestion, inhalation, injection, and the skin.’²⁰ Further: ‘For firefighters, the main route of entry is usually by the respiratory system, especially at incidents.’²¹A more significant source of exposure is likely to be AFFF entering the drinking water supplies of the fire departments and their communities.

‘A study of a group of Australian firefighters in 2014 indicated PFC levels in ranges six to 10 times higher than that of the Australian population. Considering that the major manufacturer as the primary source of this product ceased production in 2002, these levels are still quite high.’²²

Linda Birnbaum, former director of the National Institute of Environmental Health Sciences (NIEH), downplayed the difference in GenX and PFOA stating: ‘Every PFAS that has been studied is causing problems.’²³The NIEH agency funds scientific research into the chemicals. ‘Even if they have a shorter half-life, if it has a half-life of 30 days, it’s going to build up in your body,’ Dr Birnbaum explained. She further reported: ‘… lack of biological persistence does NOT mean lack of toxicity, particularly for chemicals like PFAS that may have consistent daily exposures.’²⁴

In 2019, the International Pollutants Elimination Network (IPEN) reported on the shorter chain versions of PFAS:

‘Spurious assertions about shorter-chain PFAS being tolerable are strongly countered by new scientific evidence of increased risk of exposure due to greater mobility, higher solubility and greater uptake into the food chain, there being no difference in extreme environmental persistence leading to increasing and irreversible exposure if releases continue.’²⁵

With no viable realistic method to contain firefighting foam, drinking-water sources have become contaminated. PFAS chemicals are extremely mobile and fast. The chemicals go anywhere that water goes. A boom is an inefficient tool for PFAS retention other than for optics to the public.

An AR-AFFF pail of C6. C6 contains more ‘short chain’ PFAS which epidemiologists believe are still extremely toxic. IPEN reported ‘increased risk of exposure due to greater mobility, higher solubility and greater uptake into the food chain, there being no difference in extreme environmental ersistence leading to increasing and irreversible exposure if releases continue.’ (Foam Exposure Committee)

Attorneys General in the United States

In the meantime, state attorneys general are putting pressure on the US Congress. New York State Attorney General James released a joint letter to Congress, signed by a coalition of 22 State Attorneys General, strongly urging the US Senate and House of Representatives to pass legislation to aid New York and other states to address the public health threat of toxic ‘forever’ chemicals.

‘Across the country, PFAS contamination is most often associated with military bases, firefighting training centers, civilian airports, and industrial facilities. PFAS chemicals tend to be persistent in the environment and have been used for decades as ingredients in firefighting foam. Some states with significant PFAS contamination are currently spending tens of millions of dollars to address the contamination in public drinking water systems, and to investigate numerous areas and sources of potential contamination. To date, New York has spent more than $51 million on PFAS cleanup-related costs and these costs will likely continue to grow.’²⁶

The same coalition also submitted comments to the US Environmental Protect Agency (EPA) supporting the agency’s plan to regulate perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), under the federal Safe Drinking Water Act. PFOS and PFOA are two members of a broad class of substances commonly known as PFAS. The states also asked the EPA to propose final drinking water standards for those specific chemicals and other PFAS that reflect current science and protect human health.

For more information, email codepfas@gmail.com

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