2017 saw South Australia propose a limited ban on PFOS and PFOA based firefighting foams. Every public consultation submission endorsed this position as a great idea. Only a third preferred a complete ban on all firefighting foams in future containing any PFAS (PerFluoroAlkyl Substances). A position seemingly popular with public sentiment, fearful of drinking water contamination from extensive historic training with legacy PFAS (C8 PFOS/PFOA) based agents at Military bases, around the nation.
Most Fire Services when considering moving to Fluorine Free Foam (F3) agents, have done so knowing that Major Hazard Facilities in their areas are protected by proven more effective fluorinated foam agents. These provide the fuel shedding capability and film forming additives critical to deliver fast, effective, efficient and reliable fire control and extinction. Leading more environmentally benign short-chain PFAS (C6) based agents have shown equivalency in effectiveness with such legacy C8 products. This ensures critical life safety of site personnel, emergency responders and the wider community are adequately protected, while also minimising the risk of escalation, reducing toxic smoke emissions, reducing foam usage and potentially noxious runoff generated. Fire Services can confidently use these fluorinated agents on sites when responding to major incidents to quickly gain control and limit damage, including to the environment. The same cannot be said of F3 agents where forceful application and fuel in depth fires are concerned. F3s are usually slower, require higher application rates, often suffer unpredictable flashbacks, can burn from fuel pick-up and may overflow containment areas, leading to wider environmental pollution from the incident.
A draft amendment issued in November 2017 by South Australia’s Environmental Protection Agency (SA EPA) called for a complete ban on PFAS containing firefighting foams across South Australia. Detailed reasoning about potential adverse consequences to life safety and incident escalation, particularly involving volatile fuel fires in Major Hazard Facilities, seem to have been overlooked. A complete PFAS firefighting foam ban was imposed for all applications across South Australia in January 2018, with a two-year period for full compliance. Was this the wisest decision? Was it a knee-jerk reaction to public fear? …What are the implications for life safety?
In stark contrast America’s Washington State similarly proposed a complete PFAS firefighting foam ban in January 2018, which passed the Senate and gained considerable support in the lower House. Further research led to compelling testimonies provided by two leading producers of F3 to the House Environment Committee. They supported the use of F3 agents for spill fires and all training. Evidence highlighted the critical problems and adverse consequences likely to be experienced, if such a blanket ban were enforced for all major hazard facility applications.
“We are actively telling people do not train with fluorinated foams, use non-fluorinated foams where ever you can, but maintain the short chain chemistry AFFFs and AR-AFFFs that need to be used for critical situations like aircraft rescue firefighting and large catastrophic Fuel-In-Depth type fires.” They explained “…the fluorine free foams are very effective on spill fires but once you get to a situation where the foam actually has to plunge below the surface because of the application techniques, the fluorine free foams actually pick up some of that fuel and by the time the foam comes to the surface after plunging below it, it actually burns”.
Consequently Governor Inslee signed into law (27th March 2018) amended legislation that restricts the sale and use of Class B firefighting foams containing PFAS, across the USA’s Washington State as follows:
- PFAS-containing foams (AFFF and AR-AFFF) may not be discharged or otherwise used for training purposes from 1st July 2018.
- Manufacturers may only sell or distribute PFAS-containing foams (AFFF and AR-AFFF) for use in Washington State for the following specific uses, from 1st July 2020:
- Airport and Military Applications where the use of a PFAS-containing firefighting foam is required by Federal law, including but not limited to military and FAA-regulated civil airports.
- Petroleum Terminals
- Oil refineries
- Chemical Plants
The use of more environmentally benign short chain C6 AFFF, meeting US EPA’s PFOA Stewardship Program (2006-15) goals minimises adverse life safety, environmental and community impacts in these specific high hazard applications. This Major Hazard Facility category is usually considered to also include all military sites and their assets (ships, aircraft, submarines, tanks etc); heliport/helidecks, aerodromes, aircraft hangars and their maintenance areas; offshore platforms and oil rigs; large oil tanker ships, cruise ships and other vessels carrying dangerous flammable liquid cargoes and associated ports/jetties where they berth; other large industrial plants with complex processing which uses significant volumes of solvents and flammable liquids (eg. Pharmaceutical Cos, Paint Cos, Plastics Cos, Metal smelting and processing Cos. etc.); plus large mine sites and specialised vehicles.
- Grave concerns were expressed over F3’s ability to extinguish major fires in process areas, oil storage tanks and aircraft crashes if a complete ban went ahead, because F3 agents lose effectiveness on Fuel-In-Depth fires and forceful application.
- Removing a vital tool such as C6 AFFF is not safe, particularly when protecting people potentially injured, trapped and facing death.
Dikes, bunding and modern management practices can collect and contain firewater runoff, preventing its discharge into the environment – providing they are not overflowed by poorer performing products taking longer and requiring higher application rates to work effectively.
This video https://www.tvw.org/watch/?eventID=2018021146 links to industry expert’s testimony.
These factors are particularly relevant when public fears about potentially severe health effects from PFAS exposure, seem not to be supported by a May 2018 Australian Department of Health Expert PFAS Panel Report to the Minister, concluding that “There is no current evidence that supports a large impact on an individual’s health.” …and “In particular, there is no current evidence that suggests an increase in overall cancer risk.” …”Differences between those with the highest and lowest exposures are generally small, with the highest groups generally still being within the normal ranges for the whole population. There is mostly limited or no evidence for an association with human disease accompanying these observed differences. The main concerning signal for life-threatening human disease is an association with an increased risk of two uncommon cancers (testicular and kidney). These associations in one cohort were possibly due to chance and have yet to be confirmed in other studies.” It also confirms that “The published evidence is mostly based on studies in just seven cohorts. These cohorts have generated hundreds of publications but there is a high risk that bias or confounding is affecting most of the results reported. …Many of the biochemical and disease associations may be explainable by confounding or reverse causation. Many studies had limited power to detect important associations.”
“After considering all the evidence, the panels advice to the Minister on this public health issue is that the evidence does not support any specific health or disease screening or other health interventions for highly exposed groups in Australia, except for research purposes. Decisions and advice by public health officials about regulating or avoiding specific PFAS chemicals should be mainly based on scientific evidence about the persistence and build-up of these chemicals.”
http://www.health.gov.au/internet/main/publishing.nsf/Content/C9734ED6BE238EC0CA2581BD00052C03/$File/summary-panels-findings.pdf links to the Report’s summary findings.
Substantial scientific evidence from the Monash University, Queensland and recent occupational exposure study of UK firefighters all confirm that the volatile breakdown products of the fire, including known carcinogenic PAH’s (Polycyclic Aromatic Hydrocarbons), like Benzo (a) pyrene, 3-MCA, and 7,12-dimethylbenz[a]anthracene, to which firefighters are being exposed, is causing increased cancer risks in firefighters as an occupationally exposed group, exhibiting higher cancer risk levels than the average population, particularly for prostate cancer and skin melanomas.
The Monash study showed 79% of the fires attended by career, paid part-time, and volunteer firefighters were in buildings, vehicles or bushfires, where water alone is normally used – Class B fluorinated foams would not be required. On the rare occasions foam is needed for large bushfires, Class A fluorine free type (without PFAS chemicals) would be used.
Perhaps other States and countries could learn from Washington’s calm, open and fair assessment of the whole fire incident, its hazards, risks, fire performance requirements and potential consequences, during their appraisal of this complicated and often controversial issue.
For more information, go to willsonconsulting26@yahoo.com.au
About the Author
Mike Willson has over 25 years experience in the fire industry across many sectors including Aviation, Refineries, Brigades, bulk fuel storage, much of it involved in flammable liquids as a technical specialist on Class B foams, their application and associated foam delivery systems.
