Firefighting Foam and PFAS (2024)

Reduce & Report the Use of Class B AFFF

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 firefighters shouldimplement all of the best management practices in the following documents:

AFFF Collection and Disposal Program

Michigan was one of states in the country to launch a state-wide Class B AFFF Pickup and Disposal Program to protect firefighters, residents and remove AFFF from the environment. As of April 2023, Michigan had collected over 60,000 gallons of AFFF. We continue to work with fire chiefs around Michigan to ensure AFFF is properly disposed.

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.

• 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.

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.

Fluorine-free AFFF

Now that we know what to look for, you can learn moreinformation on PFAS-free material from theInterstate Chemicals Clearinghouse.You may also consultGreenScreen for Safer Chemicals.

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 fluorine-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:
   • Current performance data is uncertain and/or lacking.
   • 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.
   • 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'sEnvironmental Assistance Centerat 1-800-662-9278