States are utilizing action on PFAS containing firefighting foams with take-back programs given the lack of federal direction. According to BCLP (Bryan Cave Leighton Paisler), a law firm keeping up with state regulations, ‘33 states have either enacted or proposed regulations regarding per- or polyfluoroalkyl substances (“PFAS”) present in Class B Aqueous Film-Forming Foams (“AFFF”) used for firefighting, or present in firefighters’ clothing and equipment.’1
Not all states are providing guidance or regulations on how to clean out of AFFF/PFAS for a fire apparatus foam tank. At this time, the Foam Exposure Committee (FEC) believes that a fire chief has three choices.
- Remove AFFF from the fire apparatus tank and properly dispose of it. Plug the tank.
- Contract with a licensed environmental firm to remove AFFF, ‘clean out’ the foam tank and remove the foam from the premises. Define ‘clean out!’
- Replace the complete apparatus which would still involve removing AFFF from the apparatus foam tank. Dispose of the AFFF properly according to hazmat requirements.
Fire chiefs throughout the US have already been switching away from AFFF in order to protect their communities and firefighters.
Consider the firefighter and public safety first.2
For more information, contact the Foam Exposure Committee at codepfas@gmail.com
Notes
1 BCLP, PFAS Update: State Regulation of PFAS in Firefighting Foam and Equipment,January 25, 2022, www.bclplaw.com/en-US/insights/pfas-update-state-regulation-of-pfas-in-firefighting-foam-and-equipment-1.html
2 Interstate Technology & Regulatory Council (ITRC), PFAS Technical and Regulatory Guidance Document and Facts Sheets PFAS-1, Washington, DC: Interstate Technology & Regulatory Council, PFAS Team, Updated June 2022, https://pfas-1.itrcweb.org/3-firefighting-foams/?print=pdf, p. 13 & 14
