A firefighting foam is a stable mass of small air-filled bubbles which have a density lower than oil, gasoline or water. Foam is made up of three ingredients – water, foam concentrate and air. In simple terms, when mixed in the correct proportions, these 3 ingredients form a homogeneous foam blanket that extinguishes fires by cutting one of the 3 main fire triangle sources – oxygen, heat and fuel.
Traditionally, the global firefighting foam of choice has been a fluorinated foam. However, this foam – known as the forever chemical – is high in perfluoroalkyl and polyfluoroalkyl substances (PFAS) and has been linked to health impacts and environmental contamination.
Regulators worldwide are now banning or restricting fluorinated foams where a fluorine-free firefighting foam alternative is available.
While there’s guidance from regional agencies and industry regulatory bodies available, it’s hard to find a single source of truth when it comes to finding all the information you need about changing over your foam. Here’s our go-to guide on what you need to consider when choosing a new firefighting foam.
The importance of firefighting foam
Firefighting foam is an effective fire suppression agent for fires involving flammable liquids, known as Class B fires. These are fires associated with aircraft hangars, bulk fuel storage facilities, warehousing of flammable and combustible liquids or where occupancies use a process involving flammable or combustible liquids.
Firefighting foam is used in both fixed and portable fire suppression systems as well as manual fire suppression apparatus used by attending fire brigades. When designed, installed, and maintained correctly, fire suppression systems which use firefighting foam can significantly reduce the effect of fires on life, property, the environment and business continuity.
| Foam name | Description | Status |
|---|---|---|
| C8 (legacy foam) | Legacy foam high in perfluoroalkyl and polyfluoroalkyl substances (PFOA)
The fluorinated part of the carbon chain in these C8 foam products is longer than or equal to 7 carbon atoms. |
Banned or restricted |
| C6 | Contains trace amounts of PFOA but is currently considered safe for continued use in certain jurisdictions. | Currently considered safe for use in certain jurisdictions if key parameters are met (April 2023) |
| F3 | A fluorine free foam which doesn’t contain PFOA, 100% biodegradable. Should still be contained for runoff into waterways. | Available, new products emerging regularly |
Three things to consider when replacing your firefighting foam
Firefighting performance
In a fire suppression system, the firefighting performance of any chosen foam should be independently tested and certified. A poor choice can lead to:
- Fires being difficult to extinguish and burning longer. This can lead to increased toxic combustions released and the compromised safety of building occupants, attending fire brigade and wider community.
- More foam being used. This can lead to increased fire water runoff and adverse environmental impacts.
Foam selection must be accompanied by evidence of suitability from an appropriate testing or approval body. This will confirm the performance of the firefighting foam on the fuels to be protected, type of equipment to complement the foam and likely conditions on the site.
Testing by the National Fire Protection Agency Research Foundation in 2020 demonstrated a baseline C6 foam to have equivalent or superior firefighting capabilities to F3 foams. The F3 foams typically needed an application rate of up to 3 times that of C6 foams to achieve similar results.
However, this is changing as the market matures and new F3 foams become available, with some F3 foams now having similar firefighting performance in particular circumstances, although this is dependent on the foam manufacturer.
Newer fluorine-free foams are now reporting similar firefighting performance to fluorinated foams.
Environmental Impact
Unfortunately, all firefighting foams have the potential to pollute the environment. However, some firefighting foams have a greater environmental impact due to their chemical composition.
The United Nations Stockholm Convention on Persistent Organic Pollutants (POP) aims to eliminate or restrict the production and use of POPs. To be regarded as a POP, a substance must be considered likely to lead to significant adverse human health or environmental effects. These include the capacity to:
- remain persistent in the environment
- bio-accumulate
- be toxic to humans or the environment
- have the potential for long range environmental transport.
Legacy fluorinated firefighting foams contain two POPs which are being phased out – perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA). Newer fluorinated foams, known as C6 foams, may contain trace amounts of PFOA but are kinder on the environment and currently considered safe in certain jurisdictions and uses.
Fluorine-free firefighting foams, known as F3 foams, don’t contain these harmful chemicals and are 100% biodegradable. However, short-term environmental impacts of many F3 foams have been shown to be higher in short-term aquatic toxicity than C6 foams.
In addition to choosing a firefighting foam that does as little damage as possible, it’s important to collect and manage fire water run off to reduce environmental impacts.
Health impact
Studies show that exposure to perfluorooctanoic acid (PFOA) may increase the risk of cancer.
Lab research has shown that exposure to PFOA increases the risk of certain tumors of the liver, testicles, mammary glands and pancreas.
Human research has focused on the cancer rates of people living near or working in PFOA-related chemical plants. Some studies suggest an increased risk of testicular and kidney cancer. Studies have also suggested a possible link to thyroid cancer.
Other studies have suggested possible links to other cancers but the research is inconclusive[1].
Compatibility
When engineering a fire suppression system, it’s critical that a foam works well with existing or proposed fire systems and equipment.
If you’re updating your existing fire suppression systems because it contains a legacy C8 foam, you can’t treat it as a like-for-like replacement.
The overall system must be reviewed to ensure any foam replacement will not have an adverse effect on overall system performance. Consultation with the designers of your foam suppression system and foam manufacturers will be able to say whether any modifications are necessary for the system to still perform well and be compliant.
Compatibility factors to consider when replacing your foam:
- Viscosity of the foam concentrate
- Suitability for use with existing proportioning hardware
- Compatibility with materials in the system such as rubber seals metals, plastics
- Suitability for type of fuel to be protected
- Suitability of the existing application method (aspirated, non-aspirated etc)
- Suitability for the environmental conditions, e.g., extremes of ambient temperature
- Suitability of the existing equipment expansion ratios
- Suitability of the existing equipment application rates
- Provide evidence of suitability from an appropriate testing/approval body that the selected foam is suitable for the intended application.
How to replace your existing fluorinated C8 foam
Once you’ve carried out a comprehensive engineering analysis of existing systems which helps you understand the impact of foam replacement, here’s how to change out your foams:
- Decant existing C8 foams and store in a bunded area.
- Thoroughly flush existing systems with water and collect the effluent. Store in a bunded area. You may need multiple flushes to reduce the level of PFAS in the water supply to acceptable levels. Follow established guidelines for this. If full removal from flushing isn’t possible, consider infrastructure replacement.
- Replace required equipment, e.g. foam proportioning and delivery technology has drastically changed over the past 20 years, and more reliable systems are now available on the market than traditional bladder and pumped proportioning equipment.
- Send C8 foam, effluent and redundant equipment for safe disposal in accordance with local and industry regulatory requirements.
The extent of fire suppression system downtime will be different for each site. It’s important to recommission the system following any upgrades and modifications. This validates system functionality and performance.
How to maintain your fire protection system
There’s no differences in routine maintenance of fire protection systems when transitioning from a C8 to a C6 or F3 foam. International and local regulations cover the maintenance requirements you need to follow. These include AS1851 and NFPA 11.
The former requires fire suppression systems to discharge foam in a test, every 5 years. Tests also demand appropriate storage, collection containment and treatment and disposal of foam and wastewater.
The regulations relevant to your region, state or country
In every juristriction, you should refer to the latest guidelines from your local environmental agency, e.g. the Environmental Protection Agency (EPA) and your national fire industry association, e.g. Fire Protection Association (FPA).
While the tables below aim to highlight high-level requirements, there will be certain instances where the below regulations will vary, e.g. crown land, airports and defence bases, which may have their own sets of guidelines which are to be followed in tandem with state legislative requirements.
This information is correct as of April 2023. Please be aware that foam legislation for each jurisdiction is a highly moving part and updated regularly. Please check your local environmental agency or fire industry association for the very latest requirements.
Australia
| Region | Ban status |
|---|---|
| Queensland |
|
| New South Wales | NSW is currently in a transitionary phase, all information below is applicable as of April 2023:
The N.S.W government has also endorsed the use of the PFAS National Environmental Management Plan 2.0 which aims to:
|
| South Australia | Complete ban on all fluorinated foams including C6, with these specifications:
Exemptions to the above by application and where it can be demonstrated F3 foam is not a practical alternative to fluorinated foams. |
| Western Australia
Victoria Australian Capital Territory Northern Territory |
Nominated governments have endorsed the use of the PFAS National Environmental Management Plan 2.0 which aims to:
|
| Tasmania | The Tasmanian government has introduced the Tasmanian PFAS action plan which broadly aims to:
This plan is regularly updated and updates to this policy should be sought from the Tas EPA website. The Tasmanian government has also endorsed the use of the PFAS National Environmental Management Plan 2.0 which aims to:
|
New Zealand
| Region | Ban status |
|---|---|
| All realms | The Environmental Protection Agency (EPA) has implemented a ban on PFOS and PFOA firefighting foams: • All sites using PFOA firefighting foams that cannot be contained should have transitioned to an alternative foam. • Sites containing PFOA firefighting foams which can be contained must transition to an alternative foam by 3 December 2025. |
United Kingdom
| Region | Ban status |
|---|---|
| All realms | Fire fighting foams contaning PFOA:
can only be used on existing sites with already installed systems provided all discharges can be contained. Permitted from January 2023 until 4 July 2025.[1] [1] Compliance advice for PFOA in class B firefighting foams (bafe.org.uk) |
United States
| Region | Ban status |
|---|---|
| All states (including for the Department of Defense) | Several states are passing or considering legislation to restrict the use of PFAS foams, particularly for training purposes, where most usage occurs.
States allowing continued use of PFAS based foams for major hazard facilities include California, Colorado, New Hampshire, New York, Virginia and Washington. The US Department of Defense still uses flouronated firefighting foams. It’s understood that it’s currently in the process of changing legacy C8 foams with C6 foams, with the respective defence base maintenance contractors responsible for confirming any system modifications, calibration, commissioning, and confirmation of system operation following foam changeover. However, the US Department of Defense has notified foam manufacturers that they need to replace C6 foams with F3 foams of equivalent performance in the next 5 years. |
Future-proofing your firefighting foam
Considering potential future impacts of legislative change is essential when choosing your firefighting foam. Where possible, we recommend choosing a progressive foam that’s effective, compatible and also causes the least damage to people and the planet.
Here’s a quick summary of summary of how to approach changing out your firefighting foam:
- Understand what your current foams are made of.
- Get up to date with the requirements of your jurisdiction.
- When choosing a new foam, consider performance, environmental and health impacts and compatibility.
- Establish a maintenance plan and schedule to stay compliant.
- Reach out to a fire protection team for support.
[1] https://www.cancer.org/healthy/cancer-causes/chemicals/teflon-and-perfluorooctanoic-acid-pfoa.html#:~:text=Studies%20in%20humans&text=Some%20of%20these%20studies%20have,have%20been%20due%20to%20chance
[2] Compliance advice for PFOA in class B firefighting foams (bafe.org.uk)
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