The landscape around Aqueous Film-Forming Foam (AFFF) is evolving rapidly, particularly due to concerns about its environmental and health impacts.
Businesses using foam for fire suppression are increasingly navigating a complex regulatory framework, often driven by the presence of per and polyfluorinated substances (PFAS). Here’s an independent, straightforward overview of where things stand.
Why Is AFFF a Concern?
PFAS are often called “forever chemicals” due to their persistence in the environment and the human body. Studies link them to adverse health effects, including cancer and developmental issues. Consequently, regulatory scrutiny on PFAS-containing products, including AFFF, has intensified globally.
Current PFAS Situation
“In the UK, there is currently no legal restriction on the supply or refilling of current fluorotelomer based (C-6) AFFF in fire extinguishing applications including fire extinguishers.” – Source
For context, over the past decade, all AFFF products have been formulated using fluorotelomer chemistry, which does not contain PFOS, PFOA (C-8), or PFHxS. Before this shift, AFFF was likely to include PFOS or PFOA, though PFHxS was not used in firefighting foams.
Refilling fire extinguishers or fixed systems previously containing PFOS, PFOA, or PFHxS with fluorotelomer-based foam does not exempt them from the bans. These systems will still contain trace amounts of these restricted chemicals above the allowable limits.
PFAS Going Forward
The European Chemicals Agency (ECHA), the EU authority responsible for REACH restrictions, is proposing two new restrictions under REACH that would prohibit PFAS in firefighting foams within the EU.
The first restriction, concerning PFHxA, was published in the EU’s Official Journal as Regulation (EU) 2024/2462 on September 19, 2024, marking its entry into force. This restriction does not apply to portable and fixed firefighting systems, as they will be addressed under a separate firefighting foam restriction that has not yet been published.
This regulation does not directly affect the UK, except in cases of export or as part of the ongoing DEFRA/HSE consultation process, which may influence the development of a similar restriction within the UK.
UK Going Forward
In the UK, DEFRA and HSE have initiated a consultation process for a UK REACH restriction on PFAS in firefighting foams. They are currently engaging with industry stakeholders, with a public consultation planned for next year.
It is unlikely that any UK-specific restrictions will come into effect before 2026. Transition periods are expected to align with those proposed under the EU restriction, including:
- 18 months for firefighter training, system testing, and use by municipal fire brigades (excluding large industrial sites).
- 5 years for portable extinguishers, marine applications, aviation, and defence.
- 10 years for offshore platforms and major industrial sites (COMAH/Seveso III).
A complete ban on all applications is unlikely to occur before 2030 at the earliest.
The FIA Position
The FIA recommends that businesses begin planning to transition to fluorine-free agents, although there is currently no legal requirement to do so. If you decide to make this change, please ensure that you verify the equivalent fire testing approvals and application rates for the specific fuels stored or used in bulk, to avoid unintentionally compromising fire safety. Once dates are confirmed, the FIA will provide more detailed guidance.
