Q&A: PFAS-Free Firefighting Solutions | Langan
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Q&A: PFAS-Free Firefighting Solutions

What is driving increased pressure across industries to remove PFAS from firefighting foam?

The pressure is primarily being driven by heightened public awareness and an advanced understanding of the potential risks to human health and the environment posed by PFAS. For decades, Aqueous Film Forming Foam (AFFF), which contains PFAS, was the standard for effectively suppressing flammable liquid fires. However, the persistence of PFAS and the increased association with potential adverse effects to human health and the environment have led to stringent regulatory and legislative actions at both state and federal levels. Governments are enacting bans and restrictions on the manufacture, sale, and use of PFAS-containing foams, often starting with prohibiting use in training exercises to prevent or minimize environmental releases. These regulations create a clear mandate for industries and fire services to transition to safer and effective alternatives.

What actions are businesses taking to move toward PFAS-free solutions?

In response to regulatory pressure and growing awareness, businesses and industries are actively engaged in significant transition efforts. Foam manufacturers are at the forefront, investing heavily in research and development to formulate effective fluorine-free foams (F3) that can meet performance standards without the use of PFAS. Concurrently, end-users such as municipal fire departments, airports, and industrial facilities are evaluating these F3 products, updating their standard operating procedures, and developing comprehensive transition plans. This involves the complex logistical challenge of safely collecting and disposing of PFAS-containing AFFF stocks, which requires coordination with the disposal facility, transporters, operator/generator, and others to effectively dispose of the material. Many organizations are also assessing their current firefighting equipment, as F3s may have different physical properties requiring modifications or replacement of foam proportioners, nozzles, and storage tanks to ensure proper performance. Retraining personnel on the characteristics and application techniques of F3 is also a critical step in this transition. Langan is an environmental advocate for clients, helping to identify relevant standards and obligations, manage potential PFAS-related risks, and implement cost-effective remediation solutions.

What are the advantages associated with transitioning to PFAS-free firefighting foam?

The advantages of moving to PFAS-free firefighting foam are substantial, primarily centered on mitigating the potential risks and liability associated with PFAS. Environmentally, the transition is crucial because PFAS are persistent pollutants that can impact soil, water, and air, posing long-term potential risks to ecosystems and drinking water. By switching to fluorine-free alternatives, future releases of PFAS into the environment via firefighting foam systems will be reduced and potentially eliminated. Furthermore, businesses and industries that proactively adopt PFAS-free solutions help reduce the potentially significant financial and legal liabilities associated with PFAS impacts—costly investigation, remediation, and potential litigation—while avoiding compliance-related penalties and operational disruptions.

What are the disadvantages?

Despite the compelling reasons for the transition, notable challenges and disadvantages also exist. A key concern is whether F3 can perform as effectively as the PFAS-based AFFF being replaced, especially in high-hazard, large-scale flammable liquid fire scenarios. While F3 technology is rapidly improving, differences in extinguishment speed, burn-back resistance, and vapor suppression capabilities compared to AFFF may still exist, necessitating thorough testing and careful selection of the appropriate F3 product for specific risks. The transition also involves significant costs, including the expense of purchasing F3 foam, the complex and often costly process of disposing of legacy PFAS foams, and the potential need to modify or replace firefighting equipment due to compatibility issues. While not a direct performance issue of the foam itself, the historical and ongoing environmental liabilities associated with PFAS impacts can impact insurability, and the costs and uncertainties of the transition could potentially influence insurance considerations. Generally, moving away from PFAS is seen as a de-risking activity in the long term. Finally, there is a need for vigilance to avoid a “regrettable substitution” and confirm that the alternative chemicals used in F3 do not present their own unforeseen health or environmental risks, highlighting the importance of transparency and rigorous testing of new formulations.

Daniel Bosworth is a trusted engineer with over 13 years of experience providing environmental, geotechnical, dredging, and construction management services for complex projects in the aviation, industrial, commercial, and oil & gas sectors. He has a strong background supporting airport/aviation projects and is currently leading two of the largest design-build terminal redevelopments in the U.S., managing teams covering all aspects of environmental, geotechnical, site/civil, surveying, regulated building material studies, and more. Bosworth has also managed AFFF system modifications/swap-outs and provided PFAS management for various airport tenants/operators across the country.

Ryan Hall has over six years of environmental experience across the Northeast United States. His work includes field sampling and testing programs, and subsurface soil and groundwater investigations on various industrial projects, including airports and airside facilities.

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Daniel Bosworth, PE
Associate
973.560.4485

Ryan Hall
Project Engineer
973.560.4462

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