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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.

To download a PDF copy of this information, please click here.

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.


PFAS Regulations and Restrictions for Firefighting Foams

 

Testing AFFF Foam Concentrates for PFAS Compliance

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New ECHA PFAS Regulations and Restrictions for Firefighting Foams

 

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

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New Regulations for Fluorinated Training  Foams

 

ECHA Proposed AFFF Transition Periods to F3

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New Regulations for Fluorinated Foams: Firefighter Training & System Testing

 

Additional Information

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PFAS Regulations and Restrictions for Firefighting Foams

  • UK Persistent Organic Pollutants (POPs) regulations, published by the Environment Agency (EA), cover legacy C8-PFAS chemicals, particularly PFOS, PFHxS, PFOA which were present in legacy Lightwater™ AFFF/AR-AFFFs, which ceased production in 2002/3. 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 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).

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Testing AFFF Foam Concentrates for PFAS Compliance

  • TOP Assay or TOF can also be important for any final rinse water after tank cleaning, before refilling with new F3 agents. This provides verification to regulators that the tanks are adequately clean and the new foam is not contaminated with any residual legacy PFAS above stringent acceptance levels.
  • Many foam users have a range of foam stocks which may vary in age. It is therefore important to establish whether these older stocks meet current UK POP regulations or may need to be disposed of safely using high temperature incineration (>1,100°C).
 

Oil Technics can facilitate such testing of your foam concentrates to ensure that existing foams are C6 compliant, do not contain legacy long-chain C8-PFAS chemicals (eg. PFOS, PFOA or PFHxS) and thereby would not meet current UK POPs or EU PFAS restriction regulations.

 
  • 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 could be either a TOP (Total Oxidisable Precursor) Assay, or TOF (Total Organic Fluorine) Analysis conducted at extra cost to regular 28 suite PFAS testing, but importantly verifies the total level of PFAS present in specific existing bulk foam tank stocks.
  • This is also a valuable test to conduct on final rinse water when cleaning foam storage tanks, to ensure 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 1ppm 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 firefighting foams.
  • However, considering the high cost of removing last contamination in complex offshore systems, SEAC supported a higher residual limit value of 50ppm 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 does not conform with current Environment Agency (EA) restrictions, must be:
  • notified to the EA
    
  • quarantined, labelled and no longer used
  • safely disposed of appropriately to EA requirements (ie. high temperature incineration >1,100°C)
 
 

We can offer Total Oxidizable Precursor (TOP) Assay testing to ensure foam concentrates comply with local regulations and policies. We only require 250 mL of foam concentrate to determine PFAS levels.

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

To enquire about having your foam TOP Assay tested, please click here.

 

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New ECHA PFAS Regulations and Restrictions for Firefighting Foams

 

All Aberdeen AFFF Firefighting Foams are stringently monitored during production to ensure they meet acceptably low trace quantities of PFOA and other PFAS of concern, which are well below threshold levels, so they fully comply with all current regulations

 
  • UK Persistent Organic Pollutants (POPs) regulations (ratifying the UN Stockholm Convention) published by the Environment Agency, 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).
  Component
Allowable Limits under UK POPs Regulations
Allowable Limits under EU POPs Regulation 2019/1021
  • PFOS or its salts
10 ppm salts and related substances combined 10 ppm salts
  • PFOS-related substances
Included above   1000 ppb
   
  Component
Allowable Limits under UK POPs Regulations and EU Regulation EC 2017/1000
  • PFHxS or its salts
25 ppb
  • PFHxS-related substances
  1000 ppb
   
  • PFOA or its salts
25 ppb
  • PFOA-related substances
  1000 ppb
   
  • 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 residual levels:.
  Component
Allowable Limits under UK POPs Regulations and EU Regulation EC 2017/1000
  • PFHxA and its salts
25 ppb
  • PFHxA-related substances
  1000 ppb
   
  • PFAS levels within foam concentrates are measured using an advanced TOP Assay analysis method. 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 above for more information.

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

 

ECHA's Committee for Socio-Economic Analysis (SEAC) are recommending a 10 year derogation for the use of C6 AFFF-LF Foams in the North Sea, bringing it in line with high hazard Seveso III sites. 

 

  • 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 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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New Regulations for Fluorinated Training Foams

  • ECHA is proposing that firefighting foams containing above 1 ppm (mg/L) PFAS shall not be used for training or system testing 18 months after entry into force (except functional testing, where all foam used should be collected and disposed of safely).
  • Aberdeen Foam can offer its customers a choice of fluorine free foams for training purposes:

1% Training Foam

 

3% Training Foam

Fluorine Free Training Foam

Find out more

 

Fluorine Free Training Foam

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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):        

   

Sector/type of use or placing on the market

   

Transitional period after entry into force†

   

 
  • Seveso III establishments

 

10 years

 
 
  • Offshore installations

 

10 years*

 
 
  • Civilian aviation

 

 5 years

 
 
  • Defence

 

 5 years

 
 
  • Municipal fire services

 

 18 months

 
 
  • Ready-to-use applications

 

 5 years

 
 
  • Marine applications

 

 5 years*

 
 
  • Other industries

 

 3 years

 
 
  • Foam for training and testing

 

 18 months*

 
 
  • Formulation

 

 10 years

 
* As detailed above, this transition period is currently a recommendation by SEAC.
†These periods have been proposed, but some may gain possible extension following consideration of public consultation submissions

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New Regulations for Fluorinated Foams: Firefighter Training & System testing (proportioning)

  • The European Commission (EC) recommends immediate withdrawal of fluorinated foams used for training, calibration and proportioning.
  • The EC has proposed a ban on the use of fluorinated foams for training, system testing and calibration with 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.
    
 

Oil Technics can offer its customers a range of Aberdeen Fluorine Free Foams for both training and system testing or calibration to verify proportioner accuracy:

 
 

1% Training Foam

 

3% Training Foam

 

Induction Foam

Fluorine Free Training Foam

Find out more

 

Fluorine Free Training Foam

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Fluorine Free System Calibration Foam

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Additional information                  

  • UK Government position
 

Read more

 
  • Mike Willson: Report on AFFF alternatives
  Download here  
  • ECHA: Safer Chemicals podcast, June 2023
  Listen online  
  • Royal Society of Chemistry: The Concept of Essential Use for Determining when Uses of PFAS can be Phased Out
  Download here  
  • DEFRA: Consultation on potential amendments to the Persistent Organic Pollutants (POPs) Regulation
  Read online  
  • DEFRA: Annex A - Supplementary evidence for amendment and/or addition of waste concentration limits (or 'low POP content limit') for several POPs
  Download here  

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