by Jonathan Strong

One of the most common tools for firefighting has been under intense scrutiny in recent years. Aqueous Film-Forming Foam is increasingly associated with cancers, immune system dysfunction, and reproductive problems. Today, AFFF is no longer the gold standard for fire suppression; its effectiveness came at the expense of nationwide health and safety. Enthusiastically, we are looking for viable alternatives, some of which have already entered the market as biodegradable and potentially safer options. To comply with state regulations and show commitment to mitigating environmental harm, fire departments are integrating fluorine-free foams into their practices. Many people raise questions on whether the new-age foams are genuinely safe or merely a lesser evil, considering the false beliefs we had about AFFF and its contents before the health crisis.

AFFF formulations were universally perceived as completely harmless and praised for their effectiveness. This primarily explains why the military and other industries recklessly employed AFFF for decades. Little did they know the fear and public outrage that would follow, because the integral components of AFFF are now recognized as some of the most persistent and toxic agents ever released into our environment; and have spread to practically every corner of our country through water supplies, soil, and wildlife. PFAS had a profound impact; they put us in a high-stakes scenario. This is precisely why we should be worried about the new-age alternatives and the unaffordability of a second crisis.

AFFF uses

Aqueous Film-Forming Foam was favored by firefighters for its effectiveness in suppressing Class B fires. The foam’s efficacy stems from its mixture of water, surfactants, and fluorosurfactants, which are a specific type of PFAS. These chemicals work together by forming a blanket over the fuel surface, blocking the oxygen supply and preventing reignition. In this mixture, you may find concentrations of PFAS ranging between 50% and 98%. When the foam is used, PFAS escape into the environment and they accumulate without breaking down, leading to gradual widespread contamination. After a while, the dangers to both wildlife and human population become visible.

It is no surprise that firefighters have higher concentrations of PFAS in their blood levels and have a higher risk of cancer diagnosis compared to the general population. This fact does not imply that the general population without direct and daily contact is not at risk, because even minimal exposure to PFAS has been linked to cancers.

We understand the particular dangers of AFFF and the broad impact of PFAS, and each state crafted its unique approach to address the issues. Michigan has taken a proactive and aggressive approach, incorporating a foam collection and disposal program that aims to mitigate contamination. There is no legislation that completely bans the use of AFFF in emergency situations, but the system features stringent reporting requirements and prohibitions. Since 2020, fire departments are required to immediately report the quantity of PFAS-containing foam utilized after the end of a fire or other incident, and the specific locations of discharge. PFAS-containing foam is expressly prohibited for training and fire departments tend to refrain from using AFFF for non-training purposes. After disposing of the old foam, Ann Arbor’s Fire Department (AAFD) purchased an alternative for Class B fires.

Military bases eagerly embrace alternatives too, since Congress directed the Department of Defense (DoD) to discontinue the use of AFFF on military installations by October 2024, with extensions until 2026. The DOD will transition to firefighting foams added on the Qualified Product List (QPL), for the recently published military specification MIL-PRF-32725.

Questions on the safety and sustainability of AFFF alternatives

Fluorine-free foams (F3 or FFF) are based on hydrocarbon surfactants and they do not contain PFAS. Essentially, they have very attractive features, because they are designed to be biodegradable and less toxic. They seem like a straightforward solution due to their absence of PFAS, and many other states are advocating for them. Many of them rely on novel compositions. Novel chemical formulations are indeed essential for innovation, but they are also inherently unpredictable; they imply unforeseeable toxicity which is especially pronounced when requirements are limited to individual compounds.

There are no specific requirements on the health and environmental hazards off FFFs as a formulation, besides the PFAS or fluorine content. This fact is concerning, because it leaves a free hand to the manufacturer to assess the toxicity of the products alone without the involvement of a third party laboratory, until a list of certified products becomes available. Until then, in the absence of a standardized approach (e.g. test protocols), we may find ourselves using heavily marketed products with insufficient oversight.

In fact, recent literature has identified between 60 and 70 commercially available products that were being marketed as ‘environmentally friendly’ AFFF alternatives. Upon further investigation, it was found that half of these products did not have legitimate approvals and were marketed strictly based on ad-hoc testing.

Another point to consider is that firefighting foams need to adhere to high-performance standards in critical situations. AFFF and FFFs have the same application techniques, but the most commonly used FFFs take 1.5 longer than AFFFs to extinguish fires. They rely solely on a bubble blanket to smother fire, which degrades more rapidly. Firefighters need more training on application techniques in order to adapt to the distinct behaviors and properties of F3 foams; this may introduce the need to incorporate additional chemicals into the formulations in the future.

There is no doubt that replacing AFFF is crucial, but we are still in the dark about the drawbacks and advantages of the replacements. All foams will have some level of environmental impact, and it may be hard to strike a balance between effective firefighting and environmental safety.

About the Author

Jonathan Sharp is a Chief Financial Officer responsible for case evaluation, financial analysis, and assets management at Environmental Litigation Group, P.C. The law firm headquartered in Birmingham, AL, assists victims of toxic exposure, predominantly civilian and military firefighters.