94309_AFFF_FactSheetE:AFFF 2/10/17 12:29 PM Page 1

1001 19th Street North

Fire Fighting Suite 1200

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Foam Coalition [email protected]
www.fffc.org

2017

FACT SHEET ON AFFF FIRE FIGHTING AGENTS

Nearly 15 years after the end of production of PFOS-based AFFF agents, there is continued discussion within the
fire protection industry on the environmental impact and efficacy of fire fighting foams. The discussion of environmental
impact is usually focused on foams that contain fluorochemicals, while the discussion of efficacy is usually focused
on foams that do not contain fluorochemicals. The Fire Fighting Foam Coalition (FFFC) has produced this fact sheet to
provide you with accurate, up-to-date information about these issues.

Key Facts
● All modern AFFF agents contain fluorotelomer-based fluorosurfactants.
● Fluorotelomer-based AFFF agents are the most effective foams currently available to fight flammable liquid
fires in military, industrial, aviation, and municipal applications. They provide rapid extinguishment,
burnback resistance, and protection against vapor release.

● Fire test results presented at international fire protection conferences in 2011, 2013 and 2016 all show that
AFFF agents are significantly more effective at extinguishing flammable liquid fires than fluorine-free foams.
● Fluorotelomer-based foams do not contain or break down into PFOS (perfluorooctane sulfonate) or homo-
logues of PFOS such as PFHxS (perfluorohexane sulfonate).

● Fluorotelomer-based foams are not made with PFOA (perfluorooctanoic acid) or any PFOA-based products,
but may contain trace quantities as an unintended byproduct of the surfactant manufacturing process.

● The short-chain (C6) fluorosurfactants that have been the predominant fluorochemicals used in fluorotelomer-based
AFFF for the last 25 years are low in toxicity and not considered to be bioaccumulative based on current reg-
ulatory criteria.

● Foam manufacturers have transitioned or are in the process of transitioning to the use of only short-chain
(C6) fluorosurfactants in their fluorinated foam products.

● Proposed regulations on long-chain (≥ C8) perfluorinated chemicals (PFAS) in Canada, the European Union,
and the United States allow for the use of short-chain (C6) fluorochemicals as alternatives to long-chains in
foam and other applications. These regulations do not restrict the use of existing stocks of fluorotelomer-
based foams.

● Foam and fluorochemical manufacturers are promoting the use of best practices in order to minimize
emissions of fire fighting foams to the environment. Best practices include the containment and treatment
of foam discharges and the use of non-fluorinated fluids and methods for training and the testing of foam
equipment.
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Efficacy minutes before degrading. Similar results from a series

of foam degradation tests on AFFF agents and fluo-
At the 2011 SUPDET Conference, the Naval rine-free foams were published in International Fire
Research Laboratories (NRL) presented results of fire Fighter in 20126.
testing of AFFF agents and fluorine-free foam1.
Although the testing was limited in scope, it provided Fluorine-free foams are inherently oleophilic (fuel
clear evidence of the importance of film formation to attractive). In the absence of oleophobic (fuel-
foam performance. Extinguishment times for AFFF repelling) fluorosurfactants, fluorine-free foam can eas-
agents on 28ft2 pool fires tested at full strength were ily pick up fuel and the contaminated foam degrades
on average 77% faster for gasoline, 88% faster for quickly and becomes flammable. This fuel contamina-
methylcyclohexane (MCH), and 70% faster for hep- tion problem compromises the fire performance and
tane when compared to fluorine-free foam. For isooc- severely limits the application of fluorine-free foams.
tane, where the tested AFFF agents were unable to
form a film, fluorine-free foam extinguished the fire In July 2016 the Singapore Aviation Academy (SAA)
about 10% faster. and the International Aviation Fire Protection
Association (IAFPA) jointly organized a firefighting
AFFF agents extinguished all gasoline and heptane foam seminar7. The major focus of the seminar was on
fires in less than 30 seconds, the time required to pass the advantages and disadvantages of fluorine-free foam
the United States military specification (milspec). The versus short-chain (C6) AFFF agents. One of the
fluorine-free foam was unable to extinguish any gaso- highlights of the seminar was a planned fire test
line or heptane fire in less than 30 seconds. Foam demonstration scheduled with fluorine-free foam on
agents must meet the requirements of the milspec in an ICAO level B fire. This was of great interest to
order to be listed on the US Department of Defense many of the delegates, some who have had difficulty
(DoD) qualified products database (QPD) and used replicating tests showing that fluorine-free foams can
for military applications2. The Federal Aviation pass ICAO level B. Unfortunately, the planned
Administration (FAA) requires all US airports to carry demonstration of fluorine-free foam was run instead
AFFF agents that meet the milspec and are listed on with a short-chain (C6) AFFF. According to the com-
the QPD3. In addition many national authorities out- pany sponsoring the fire test demonstration, the fluo-
side of the US require the use of AFFF agents that rine-free foam test was not undertaken because “too
meet the milspec. many environmental factors were not under our con-
trol.” Not surprisingly, several delegates noted, “those
At the 2013 Reebok Foam Conference, VS Focum variables usually happen during fire incidents.” The
summarized the company’s development of a fluorine- short-chain (C6) AFFF agent had no problem extin-
free foam agent4. The presentation contained side-by- guishing the ICAO level B fire in the required time,
side test data done at the same facility under the same despite the environmental factors.
conditions comparing the fire performance of AFFF
agents and fluorine-free foams. The results showed Also during this seminar, foam manufacturer
that AFFF agents performed significantly better than ICL/Auxquimia presented results from a series of new
fluorine-free foams in spray extinction tests (0.785m2) fire tests run on five commercially available short-
and pan fires ranging in size from 0.25m2 to 7.06m2. chain (C6) AFFF agents and five commercially avail-
able fluorine-free foams. The tests were run with four
At the 2016 American Chemical Society Symposium, different fuels: gasoline, heptane, Jet A1, and diesel.
NRL presented additional test data comparing AFFF The results showed that AFFF agents performed sig-
agents and fluorine-free foams5. In pool fire tests, an nificantly better than fluorine-free foams on all fuels
AFFF agent achieved extinguishment in less than half except diesel. None of the fluorine-free foams were
the time (18 seconds) compared to fluorine-free foam able to extinguish the Jet A1 fire, which is the fuel
(40 seconds). In foam degradation tests, fluorine-free used in the ICAO fire tests that determine the accept-
foam degraded after 1-2 minutes while AFFF lasted 35 ability of foams for airport use in many countries.
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Enviromental Impact selective developmental toxicant. In addition it was

clearly shown to be neither genotoxic nor mutagenic.
The environmental impact of AFFF-type fluorosurfac- In 2011 results were published from a 24-month
tants has been extensively studied and a large body of combined chronic toxicity and carcinogenicity study,
data is available in the peer-reviewed scientific litera- which demonstrated that under the conditions of this
ture. The bulk of this data continues to show that study PFHxA was not carcinogenic in rats and its
short-chain (C6) AFFF fluorosurfactants and their chronic toxicity was low18.
likely breakdown products are low in toxicity and not
considered to be bioaccumulative or biopersistent In 2014 an independent report was published that
according to current regulatory criteria. assessed several short-chain (C6) fluorinated chemicals
with regard to the criteria used to define persistent
Groundwater monitoring studies have shown the pre- organic pollutants (POPs)19. The report assessed these
dominant breakdown product of the short-chain (C6) chemicals based on the four criteria that must be met
fluorosurfactants contained in fluorotelomer-based to be considered a POP under the Stockholm
AFFF to be 6:2 fluorotelomer sulfonate (6:2 FTS)8. A Convention: persistence, bioaccumulation, potential
broad range of existing data on 6:2 FTS indicate that for long-range transport, and adverse effects (toxicity
it is not similar to PFOS in either its physical or eco- and ecotoxicity). It concludes that none of the chemi-
toxicological properties9,10,11,12. Recent studies on AFFF cals meets the criteria to be considered a POP, and at
fluorosurfactants likely to break down to 6:2 FTS most they only meet one of the four criterion. The
show it to be generally low in acute, sub-chronic, and report also concludes that the three short-chain (C6)
aquatic toxicity, and neither a genetic nor develop- fluorotelomer intermediates and PFHxA “are rapidly
mental toxicant. Both the AFFF fluorosurfactant and metabolized and eliminated from mammalian sys-
6:2 FTS were significantly lower than PFOS when tems. None of these materials appear to bioaccumu-
tested in biopersistence screening studies that provide late or biomagnify based on laboratory data and avail-
a relative measure of biouptake and clearance13. able field monitoring data, and none show severe toxi-
city of the types that would warrant designation as
Aerobic biodegradation studies of 6:2 FTS in activat- POP.”
ed sludge have been conducted to better understand
its environmental fate14. These studies show that the An extensive compilation of peer-reviewed and other
rate of 6:2 FTS biotransformation was relatively slow relevant available data on short-chain PFASs can be
and the yield of all stable transformation products was found at the following link:
19 times lower than 6:2 fluorotelomer alcohol (6:2 https://fluorocouncil.com/resources/research
FTOH) in aerobic soil. In particular, it was shown
that 6:2 FTS is not likely to be a major source of per- Conclusions
fluorocarboxylic acids or polyfluorinated acids in
wastewater treatment plants. Importantly neither 6:2 Fluorotelomer-based AFFF agents are the most effec-
FTOH nor PFHpA (perfluoroheptanoic acid) were tive agents currently available to fight class B, flamma-
seen in this study. ble liquid fires. They do not contain or breakdown
into PFOS and are not likely to be a significant source
PFHxA is a possible breakdown product and contami- of long-chain perfluorochemicals. They do contain
nant that may be found in trace quantities in fluo- fluorosurfactants that are persistent, but are not gener-
rotelomer-based AFFF. Extensive data on PFHxA pre- ally considered to be environmental toxicants. AFFF
sented in 2006 and 2007 gave a very favorable initial and fluorochemical manufacturers are in position to
toxicology (hazard) profile15,16,17. Testing was done on meet the requirements of upcoming regulations with
four major toxicology end points: sub-chronic toxicity short-chain (C6) fluorosurfactants that provide the
in rats, reproductive toxicity in rats, developmental same fire protection characteristics with reduced
toxicity in rats, and genetic toxicity. Results show that environmental impacts.
PFHxA was neither a selective reproductive nor a
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References
1
Extinguishment and Burnback Tests of Fluorinated and Fluorine-free Firefighting Foams with and without Film Formation, Bradley Williams,
Timothy Murray, Christopher Butterworth, Zachary Burger, Ronald Sheinson, James Fleming, Clarence Whitehurst, and John Farley, Naval
Research Laboratory, Washington, DC, presented at the 2011 SUPDET Conference
2
United States Department of Defense Military Specification, Mil-F-24385, “Fire Extinguishing Agent, Aqueous Film Forming Foam”
3
Federal Aviation Administration, National Part 139 CertAlert No. 11-02, Identifying Mil-Spec Aqueous Film Forming Foam (AFFF), February
15, 2011
4
A New High Performance Newtonian Fluorine-Free Foam, Manual Acuna, VS Focum, presented on March 19, 2013 at the 5th Reebok
International Foam Conference
5
Evaluating differences in foam degradation between perfluoroalkyl and fluorine-free foams for the development of environmental friendly fire
fighting alternatives, Katherine Hinnant, Ramagopal Ananth, Michael Conroy, and Bradley Williams, Naval Research Laboratory, Washington,
DC, presented at the March 2016 ACS Symposium
6
Flammability and Degradation of Fuel – contaminated Fluorine Free Foams, Chang Jho, International Fire Fighter, 41, Issue 36 – November,
2012
7
Can F3 agents take the fire security heat?, Mike Wilson, International Airport Review, Vol. 20, Issue 6 (2016)
8
Quantitative Determination of Fluorotelomer Sulfonates in Groundwater by LC MS/MS, Melissa M. Schultz, Douglas F. Barofsky and Jennifer
Field, Environmental. Sci. Technol. 2004, 38, 1828-1835
9
DuPont 2007a. H-27901: Static, Acute 96-Hour Toxicity Test with Rainbow Trout, Oncorhynchus mykiss. Unpublished report, DuPont-21909
10
DuPont 2007b. H-27901: Static, Acute 48-Hour Toxicity Test with Daphnia magna. Unpublished report, DuPont-21910
11
DuPont 2007c. H-27901: Static, 72-Hour Growth Inhibition Toxicity Test with the Green Alga, Pseudokirchneriella subcapitata. Unpublished
report, DuPont-22048
12
DuPont 2007d. H-27901: Early Life-Stage Toxicity to the Rainbow Trout, Oncorhynchus mykiss. Unpublished report, DuPont 22219
13
Serex, T. et al, 2008. Evaluation of Biopersistence Potential Among Classes of Polyfluorinated Chemicals using a Mammalian Screening
Method. SOT 2008 Poster #958
14
6:2 Fluorotelomer sulfonate aerobic biotransformation in activated sludge of waste water treatment plants, Ning Wang, Jinxia Liu, Robert C.
Buck, Stephen H Korzeniowski, Barry W. Wolstenholme, Patrick W. Folsom, Lisa M. Sulecki, Chemosphere 2011, 82(6), 853-858
15
Chengalis, C.P., Kirkpatrick, J.B., Radovsky, A., Shinohara, M., 2009a A 90-day repeated dose oral gavage toxicity study of perfluorohexanoic
acid (PFHxA) in rats (with functional observational battery and motor activity determinations). Reprod. Toxicol. 27, 342-351
16
Chengalis, C.P., Kirkpatrick, J.B., Myers, N.R., Shinohara, M., Stetson, P.I., Sved, D.W., 2009b Comparison of the toxicokinetic behavior of
perfluorohexanoic acid (PFHxA) and nonafluorobutane -1-sulfonic acid (PFBS) in monkeys and rats. Reprod. Toxicol. 27, 400-406
17
Loveless, S.E., Slezak, B., Serex, T., Lewis, J., Mukerji, P., O’Connor, J.C., Donner, E.M., Frame, S.R., Korzeniowski, S.H., Buck, R.C.,
Toxicological evaluation of sodium perfluorohexanoate. Toxicology 264 (2009) 32–44
18
A 24-Month Combined Chronic Toxicity/Carcinogenicity Study of Perfuorohexanoic Acid (PFHxA) in Rats, H. Iwai, M. Shinohara, J.
Kirkpatrick, J.E. Klaunig, Poster Session, Society of Toxicologic Pathology, June 2011 and Evaluation of the Chronic Toxicity and
Carcinogenicity of Perfluorohexanoic Acid (PFHxA) in Sprague-Dawley Rats, James E. Klaunig, Motoki Shinohara, Hiroyuki Iwai, Christopher
P. Chengelis, Jeannie B. Kirkpatrick, Zemin Wang, and Richard H. Bruner; Toxicologic Pathology, 43: 209-220, 2015
19
Assessment of POP Criteria for Specific Short-Chain Perfluorinated Alkyl Substances, Environ International Report, January 2014, Update
published in December 2016