Aqueous film forming foam (AFFF) that contain PFAS was, and in some cases still is, an effective tool for fighting fires used by the military and local firefighters to contain and control fuel-fed fires.

This legacy firefighting tool was used for decades until the mid-2000s when it was phased out for AFFF that didn’t include PFAS, which can be mobile in the environment and is increasingly regulated in soil and water. But for many years, while training facilities utilized legacy AFFF to prepare their firefighters, they also unintentionally introduced PFAS into the environment.

The Challenge

The use of AFFF at firefighting training facilities has resulted in PFAS in soil, surface water and groundwater. There is particular concern related to potential migration into water supplies and human exposure. As the human health and ecological risks from PFAS are becoming understood, state regulations are evolving with initial federal mandates expected sometime in 2023. The EPA has issued a number of Health Advisory (“HA”) levels for four PFAS (PFOA, PFOS, GenX, and PFBS).

The Effect

Eleven states currently have some regulatory ban on PFAS containing products. Twenty-four states have banned firefighters from training with heritage AFFF or otherwise restrict its use. Litigation has followed these developments. Firefighting facilities are considering how to dispose of heritage AFFF and address associated contamination. PFAS related liabilities and related costs are significant challenges for the training facilities, and some may not even be aware of PFAS contamination on their properties.

The Solution

Start cleaning up fire training facilities. PFAS contamination creates a unique challenge for all fire departments that will eventually need to be managed. This will be especially true if federal MCLs are put in place, which are expected this year. Environmental scientists and engineers are great resources for identifying contaminated areas, understanding regulatory requirements, and designing a remediation strategy. There are successful PFAS remediation approaches for these types of sites in the US. The more aware these training facilities are of the issue unique to their site, the better they can find the help they need and address it.