Class B firefighting foams sold today may fall under new guidelines and regulations than previous formulations in terms of allowed fluorosurfactant components. Some of these regulations are voluntary while others are mandatory. This can vary based on your authority have jurisdiction (AHJ) and/or the environmental regulation that applies in your area. The need for these requirements is in response to environmental concerns. For information on surfactants in firefighting foam and how they impact the environment, please consult “Fluorochemicals in Firefighting Foam and the EPA” published by Dyne July 2015.
Please note that throughout this document the terms C6 and C8 refer to 6 chain and 8 chain carbon fluorochemicals respectively. Perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) are types of C8 fluorochemicals.
A Brief History
In 2002, 3M voluntarily stopped the manufacturing of their Light Water™ AFFF and AR-AFFF agents because they were made with fluorosurfactants that contained and broke down to PFOS, and in some cases PFOA. All other US foam brands are made with telomer-based fluorosurfactants that do not contain or breakdown to PFOS. Telomer-based fluorosurfactants are not made with PFOA but may contain trace quantities as an unintended byproduct of the manufacturing process. In response to the US EPA voluntary PFOA Stewardship Program, most US foam manufacturers have transitioned to the use of only short-chain (C6) telomer-based fluorosurfactants that do not breakdown in the environment to PFOA.
The production and importation of PFOS-based foams is banned virtually worldwide. The European Union and Canada banned the use of existing stocks of PFOS-based foams in 2011 and 2013, respectively. Furthermore, the European Union has mandatory requirements on the use of PFOA starting in 2020 under EU 2017/1000. At that time, all foams sold in the EU will need to contain less than 25 ppb of PFOA and less than 1000 ppb of a combination of PFOA-related substances. Although it is legal to continue to use existing stocks of PFOS-based foams in the US, users should strongly consider removing them from service and properly disposing of them based on liability concerns. One approval agency, Underwriters Laboratories (UL), currently does not have any requirements on fluorosurfactant ingredients to be listed according to the seventh edition of UL162 “Foam Equipment and Liquid Concentrates.” However, other approval agencies have started to set requirements. Factory Mutual (FM) does require C6 compliant foams for new approvals and the US Military Specification is expected to adopt an amendment soon to limit PFOA to 1000 ppb.
End User Testing Requirements
Currently, neither the 2016 edition of the National Fire Protection Association (NFPA) 11 “Standard for Low- Medium-, and High-Expansion Foam” nor the 2015 edition of NFPA 16 “Standard for the installation of Foam-Water Sprinkler and Foam-Water Spray Systems” have any requirements on the type of fluorosurfactants in Class B foams. NFPA 25 “Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection
Systems” has not adopted any requirement on testing for the presence of PFOA in existing systems. Your local AHJ, however, may require additional requirements in additional to NFPA in regards to your foam system maintenance.
What companies can test for the presence of PFOS/PFOA in my firefighting foam?
Dyne currently does not offer any fluorosurfactant identification services. There are a variety of other companies, however, that can test for the presence of PFOS, PFOA, and other C8 fluorosurfactants:
*Labs accredited by the United States Department of Defense (DoD) to test for PFAS by LCMS/MS according to QSM 5.1 Table B-15.
Does Dyne recommend any of these laboratories?
Dyne does not currently recommend any particular laboratory. We do suggest you review the information in this datasheet and your AHJ requirements before making a decision. Keep in mind the manufacturer of the firefighting foam might be able to assist you in identifying fluorosurfactant ingredients provided you have the lot number for your product. Also remember that the predominant US based manufacturer (3M) quit manufacturing foam with PFOS more than 15 years ago. Manufacturers that used fluorosurfactants made from telomer based processes years ago will not contain PFOS but may contain other C8 fluorosurfactants and trace levels of PFOA. Today, most foam producers are only using C6 fluorosurfactants with ppb levels of PFOA.
Also consider the exact chemicals you are testing for. Are you just checking for PFOS/PFOA or other C8 fluorosurfactants as well? To ensure your foam is almost free of all but trace levels of the commonly used C8 fluorosurfactants, you may need to carefully review test detection limits and substances that are included in any analytical series. Please pay attention to the detection limit of the testing company you chose to use. Testing in the single digit ppb range should be acceptable but your local AHJ may have additional requirements. Note that the FFFC is presently working to establish a method and publish a technical bulletin in the first half of 2018 related to this testing.
More information on this topic can be found through governing bodies such as the NFPA and the EPA, firefighting foam manufacturers, fluorosurfactant manufacturers, the FFFC, and Dyne Fire Protection Labs
© 2017 Dyne Technologies, LLC