Firefighting Foam Update Summary

An explanation of recent changes in the UK and European Law affecting Firefighting Foam.

This brief overview highlights the most important firefighting foam developments - ensuring you are kept informed.

It is important to us that you are kept informed and encouraged to remain within UK firefighting foam regulations.

Although every effort has been made to ensure this information is accurate, if you have any extra questions to those answered below or would like any further details on any of the content provided, please don't hesitate to contact us.

10 Year Derogation for C6 AFFF-LF Foams used on Offshore Installations

• This SEAC recommendation will be forwarded to ECHA who will publish their final opinion, forwarding it to the European Commission for review.
• SEAC have considered feedback from over twenty companies and industrial bodies connected with the firefighting profession - including firefighting foam manufacturers such as ourselves.

• The decision follows SEAC’s previous approval of a ten-year derogation period for use of C6-AFFFs for sites covered by the Seveso III Directive.

• The above information appears to infer that Oil Technics, Offshore Energies UK and other’s compelling submissions for the offshore industry to be given special consideration may have been accepted.

• In a recent podcast for ECHA's Safer Chemicals, chair of SEAC Maria Ottati stated:

“… a review of available fluorine-free alternatives [to AFFF] … would be needed for uses at offshore installations in the oil and gas industry, where SEAC is recommending to lengthen the transition period from five to 10 years. The committee considers the reviews important to maintain safety where fires may have high impacts on the environment and human health.”

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ECHA Proposed AFFF Transition Periods to F3

• ECHA has proposed the following transition periods from Fluorinated Foams to Fluorine Free Foams (F3).
• Transition periods vary depending on sector and were based on availability of suitably effective alternatives, capacity for containment of releases during use (eg. bunding) and time required to practically implement transitions (including system design adaptation, equipment changes, availability, cleanout during shut-down/maintenance periods etc):       

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New Regulations for using Fluorine Free Foams for Training & System Testing (Proportioning)

The European Commission (EC) recommends immediate withdrawal of fluorinated foams used for firefighter training and system calibration and proportioning testing.

• The proposed ban on the use of fluorinated foams for training, system testing and calibration has a derogation period of just 18 months (reflected in the ECHA Transition Periods Table above), but is recommending this is implemented as soon as practically possible.
• This recommendation applies to all firefighting foams containing above 1ppm (mg/L) PFAS.
• Exception is given for functional testing where all foam used is fully contained, collected and disposed of safely according to regulations.

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New ECHA PFAS Regulations and Restrictions for Firefighting Foams

UK Persistent Organic Pollutants (POPs) regulations, published by the Environment Agency (EA), cover legacy C8-PFAS chemicals:

• PFOS
• PFHxS (defined by UN OECD as C8-PFAS), and
• PFOA (previously present in legacy Lightwater™ AFFF/AR-AFFFs from ElectroChemical Fluorination process, which ceased production in 2002/3 outside China and perhaps Russia).

Most of these legacy foams have already been removed from service and disposed of safely in accordance with EA regulations.

• PFOA can also breakdown from Fluorotelomer based AFFF/AR-AFFFs, which ceased production at end 2015.
• Companies are required to identify and produce an inventory to UK EA of any POP stockpiles where C8-PFAS chemicals, including PFOA, are measured and confirmed to be above relevant contamination thresholds.
• All Aberdeen foams purchased since end 2015 comply with strict current UK/EU regulations, requiring any residual PFOA in firefighting foams to be below acceptance levels (ie. less than 25 ppb [µg/L] PFOA and its salts, and less than1,000 ppb of PFOA related substances, including pre-cursors).

• UK Persistent Organic Pollutants (POPs) regulations, ratifying the UN Stockholm Convention and published by the Environment Agency in March 2022, require companies to identify and produce an inventory of POP stockpiles where C8-PFAS is measured and confirmed to exceed relevant acceptance thresholds.
• Any such foam concentrates must be removed from use immediately, notified to EA, quarantined and labelled prior to safe disposal by high temperature incineration (above 1,100°C in accordance with EA requirements)..

• In addition to PFOA, REACH has published its draft proposal on the restriction of PFHxA, its salts and related substances in the European Commission Comitology register with proposed restriction for firefighter training, testing and Municipal Fire Brigades in 18 months and firefighting foams for Civil Aviation after five years (from implementation), with residual levels:

• PFAS levels within foam concentrates can be measured specifically (using regular 28 PFAS suite analysis), or collectively (using an advanced TOP Assay analysis method for TOTAL PFAS content).
• Even modern C6 foams, if stored in tanks with residual C8 foam, could cause non-compliance.
• Oil Technics can facilitate testing of your foam concentrate to ensure compliance: see below for more information.

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Testing AFFF Foam Concentrates for PFAS Compliance

• TOP (Total Oxidisable Precursors) Assay or TOF (Total Organic Fluorine) can also be important for any final rinse water after tank cleaning, before refilling with new F3 agents, to provide verification to regulators that the tanks are adequately clean and the new foam is not contaminated with any unintended residual legacy PFAS (above stringent acceptance levels).

• Many foam users have a range of foam stocks which may vary in age, may have mixed brands, or contain different batches present. It is therefore important to establish whether these older stocks meet current UK POP regulations. If not, they will have to be disposed of safely using high temperature incineration (>1,100°C).

• Oil Technics foam testing service can arrange PFAS content testing of specific foam concentrates for which you may have concerns, which can be conducted at competitive rates. This will be carried out by specialised and approved laboratories qualified to conduct such PFAS content analysis on your behalf, with a report on the regular 28 suite PFAS assessment (identifying how much PFOS, PFOA, PFHxS and other common legacy PFAS may be present), with analysis report provided accordingly.

• However, firefighting foams often contain a variety of more difficult to determine pre-cursor chemicals which degrade over time to known end-point PFAS, like PFOS and PFOA. To quantify the amount of these PFAS pre-cursors present an additional analysis is required.

• This additional analysis could be either a TOP Assay or TOF Analysis, conducted at extra cost to regular 28 suite PFAS testing, but importantly verifies the total level of PFAS present in any specific representative sample of existing bulk foam tank stocks.

• This is also a valuable test to conduct on final rinse water when cleaning foam storage tanks, to verify residual levels of PFAS do not exceed Authority’s requirements.

• This analysis (TOP or TOF) can also be used to verify that any replacement Fluorine Free Foams (F3) being purchased do not unintentionally or inadvertently contain PFAS beyond accepted trace levels, before decanting into pre-cleaned storage tanks.
• EU acceptance levels in ECHA’s (European Chemicals Agency) recent SEAC (Socio-Economic Analysis Committee) draft opinion is currently 1 ppm of residual PFAS in cleaned tanks, final rinse water and new F3 concentrates. It was made clear this residual level does not provide any increase in effectiveness of foam concentrates, indicating this limit value is sufficiently low to prevent intentional use of PFAS in non-fluorinated firefighting foams.

• However, considering the high cost of removing last traces of contamination in complex offshore systems, SEAC supported a higher residual limit value of 50 ppm PFAS specifically for offshore cleanout of already PFAS contaminated foam systems.

• Testing of your foam concentrate by a qualified specialised laboratory is important to establish its composition. This will determine whether it needs replacing or not, as stockpiles of legacy C8-PFAS containing foam concentrate greater than 50 kg that do not conform with current Environment Agency (EA) restrictions, must be:

• TOP Assay is a hydroxyl radical based oxidation reaction. Precursors are transformed to end-point carboxylic or sulfuric perfluoroalkylic acids (PFAAs) in such reactions. The evaluation of pre- and post-TOP Assay data can therefore offer a clear view of total PFAS present in specific samples. Further information on this testing can be downloaded here.

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Additional information                  

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