The need to transition away from PFAS containing foams
What to do when the salesman calls and says “You need to change your AFFF because it is banned” ?
As an industry professional it does alarm me that we are hearing from some end users that they are getting that type of call, so lets start by breaking this down:
NO AFFF is not banned. There are however, already restrictions, as well as proposed further restrictions in different parts of the world that are already impacting the use not only of AFFF but of all “PFAS containing foam” – which covers ALL firefighting foams that contain flurosurfactants and fluoropolymers such as Fluoroprotein, Film Forming Fluoroprotein, Aqueous Film Forming Foam, and the Alcohol Resistant versions of these types of foam.
NO AFFF is not banned, but in most parts of the world (those countries that are signatories to the Stockholm Convention relating to Persitent Organic Pollutants (POP’s)) foams containing PFOS (a member of the PFAS family of chemicals) are NOT allowed.
NO AFFF is not banned, but within the EU and again those countries that are signatories to the Stockholm Convention are now following restrictions on the use of PFOA (C8) based foams that DO limit the use to firefighting (no testing or training) until January 1st 2023 or until July 4th 2025, if ALL foam water run off can be contained.
NO AFFF is not banned, but legislation in some US states, some Australian states and proposed legislation within the EU will impact the use and place a time limit on the deployment of the C6 based foams that have been in the market since 2016.
It is clear however that globally we are very concerned with the emission of the PFAS group of chemicals into the environment and firefighting foam when deployed contributes to this emission and accordingly end users and manufacturers understand the need to transition away from these PFAS containing foams if full containment of firewater is not possible !
Replacement of a C8 foam with a C6 is OK ?
Depending on where you are located the legislation in place (for C8 based foams) and the proposed legislation that will cover C6 you are legally allowed to make this “transition”. There are certainly some positive points for such a transition, not least the likelihood that this transition is as close to a “drop-in” replacement as you will get. There are however negatives including the cleaning / decontamination of the existing foam concentrate storage tank, and the foam system, disposal of the existing C8 foam and any contaminated water that might be created in cleaning the system. Additionally, within the EU further legislation restricting C6 is in the final stages of the legislative process, and contains regulations that aim to remove C6 from use withing 18 months to 10 years after implementation. This will then lead to a second transition to SFFF !
Why is a SFFF not a “drop-in” replacement ?
Firstly many SFFF concentrates have different physical properties compared to the PFAS containing foams they will replace and these can impact the pump, proportioner and concentrate piping between the tank and the proportioner that needs to be used with an alternative SFFF.
Secondly, it is already widely understood that the foam qualities (expansion ratio, drain time and bubble integrity) are more important with an SFFF than a PFAS containing foam and therefore it is critical to ensure that the existing discharge devices at the operating flows and pressures generate a finished foam that matches foam qualities that have been tested and proven to extinguish the fires with the fuel types used.
Thirdly, there maybe occasions when the application density with an SFFF is different to the existing PFAS containing foam. This variation will impact ALL components of the foam system, but may not be so great an issue with mobile firefighting.
How can we choose an alternative SFFF agent ?
Before addressing this question you need to answer some questions about your application and how you will deploy the firefighting foam.
- What are the hazard type – domestic / light industrial Class A / Class B, tank protection, dike protection, process equipment, loading rack, warehouse, aircraft hangar etc..
- What are the existing system(s) – fire extinguishers, hose lines, fixed/oscillating monitors, fixed nozzles, foam makers, foam chambers, sprinklers etc..
- What are the existing fuels – plus whether any plans for additional / different fuels in the future
- What was the design standard followed for the existing system – is this still applicable ?
- Are the design calculations and hydraulic calculations available for the existing system ?
Answering those questions will allow us to progress to looking at the “fire performance” we need from our SFFF foam concentrate. Fire performance can be gauged by “approvals” against recognised international fire performance test standards such as UL 162, FM 5130, EN 1568, ICAO, IMO etc.. and whilst these approvals represent good repeatable test data it is important to be aware that testing is done with a specific fuel and a nozzle designed to give good expansion of the foam bubble.
Determination of whether the SFFF foam agent can be used with existing equipment, or if changes need to be made is also an important selection criteria. With Systems it is even more critical to adopt a “holistic system” approach to the selection of alternative SFFF agent. Fixed head foam systems have to be “engineered” and require minimum available quantities of water and foam concentrate to achieve suppression. Established standards such as various NFPA standards exist but what is evident today is for the most part these standards are based on our accumulated knowledge of working with PFAS based foam agents over the past 50 years.
As a manufacturer we will only provide our recommendations in the consultation phase when we have independent third party test data to a recognised and appropriate international standard. Fomtec’s position is that recommendations without supporting data are just opinions !
The “Enviro Programme”
Fomtec has produced a number of SFFF agents for Class A and some Class B applications for many years but from the end of 2014 we have devoted significant R&D resources to the development of our “Enviro” range of high performance SFFF agents.
Its is an undisputed fact that the performance of SFFF products are more reliant on a well expanded and longer draining foam. The lack of oleophobicity, combined with greater fuel and water type sensitivity strengthens the requirement for test data. This can only be achieved through the marriage of foam concentrate with equipment into a holistic solution. Over the past 8 years we have been busy making sure our new SFFF products are tested with market leading equipment from a number of equipment manufacturers, not least the Viking Group. Our Enviro programme has (so far) resulted in almost 1000 fire tests in order to obtain the required test data to determine the operational limits of the equipment with our SFFF agents
The Enviro product range continues to grow and in May 2021 Fomtec was able to announce receiving approvals for two new products, the Fomtec Enviro USP and the Fomtec Enviro ARK. Both products are approved by UL and FM for use in sprinklers and topside devices. Fomtec Enviro ARK is a breakthrough product as it is the first fluorine free foam that is approved for use with sprinklers on polar solvent fuels. Tested and approved by FM at 3% concentration with a variety of non-aspirating sprinkler heads from Viking Corporation.
Achieving these approvals allows Fomtec to provide our clients with recommendations supported by data that is based on testing and approval by independent third parties.
So was the Salesman right?
Despite the overly enthusiastic interpretation, we should be aware that the likelihood is that within the next decade many parts of the world and most end users will NOT be able to deploy AFFF (and other PFAS containing foams).
The time to (at least plan for) transition is now!
For more information visit www.fomtec.com/
