STATUS REPORT ON ENVIRONMENTAL CONCERNS RELATED TO AQUEOUS
FILM FORMING FOAM(AFFF)

By:
Joseph L. Scheffey, P.E. and Christopher P. Hanauska, P.E.
joceJlaifue.com and hanauskaq.iThaifite.com
Hughes Associates, Inc.
3610 Commerce Drive
Baltimore, MD 21227-1652
(410) 737-8677 Fax (410)737-8688

PRESENTED FOR THE 2002 FEDERAL AVIATION ADMINISTRATION TECHNOLOGY
TRANSFER CONFERENCE
MAY 2002

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Abstract
AFFF is the primary firefighting agent used on crash rescue fire fighting vehicles to
provide protection at major U.S. airports. Recently, the 3M Company, a major producer of
AFFF, announced its decision to cease manufacturing of"PFOS" based products. AFFF is one of
these products. Production is being halted because of"PBT" concerns, that is, concerns related to
chemical persistence, bioaccumulation, and toxicity..,0M-7-manufacturers use a different process
to make AFFF. The U.S. Environmental Protection Agency is currently assessing these
chemicals.
This paper provides an update of the current status of fire fighting foam environmental
issues, including the latest position of the EPA. Environmental factors related to foam are
identified, and their relationships with current PBT concerns reviewed. The fire performance
requirements offoam for aircraft/airport protection are outlined so that users can select
appropriate alternatives to 3M AFFF. Current and future R&D efforts in the field are identified,
including efforts to reduce fluorosurfactant chemicals in AFFF, improve biodegradation of
formulations, and predict the performance offoam through modeling.

Background
Foam fire protection has been utilized in the aviation industry for many years to provide
vital fire protection at airports. In the 1970s a substantial improvement was made in the
effectiveness of foam fire protection with the development of fluorosurfactant based foams. The
fluorosurfactants are unique in their ability to reduce surface tension. These foams are now the
standard used in aircraft crash fire rescue(CFR)operations at U.S. airports.
The fluorosurfactant based foams include the following concentrates: Aqueous FilmForming Foam (AFFF), Film-Forming Fluoro-Protein (FFFP), and Fluoro-Protein (FP). These
agents are used for rapid suppression and extinguishment ofjet fuel fires resulting from an
aircraft crash. A survey conducted in 1990 by Hughes Associates, Inc. and the U.S. Navy
indicated that the twenty-four largest airports in the United States use AFFF for airport
protection [1]. While not in common usage, non-fluorosurfactant containing foams such as
protein foams may be used.
Protein-based foams were the standard for many years. In the 1960s, chemists at the 3M
Company, working with the Naval Research Laboratory, developed agents that provided surface
tension properties that allowed a thin film of water to float on hydrocarbons. This substantially
improved the fire knockdown performance of foams. From this work, the AFFF agents were
developed. It was also found that the performance of protein foam could be enhanced with the
addition of these fluorocarbon surfactants. If the surfactants are added in high enough quantity,
film formation is also possible.
The formulations of these foam concentrates are based on performance, not on the
constituents. In the U.S., the two most widely used foam specifications are Underwriters
Laboratories Inc.(UL)"Foam Equipment and Liquid Concentrates"(UL 162)[2] and the U.S.

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Military Specification(MIL SPEC, MIL-F-24385) for AFFF [3]. These specifications require .
that certain performance requirements be met in medium scale fire tests(28 and 50 square foot
pans), along with other requirements. The manufacturer determines the exact constituents that
make up a concentrate. Many U.S. airports reference the MIL SPEC when purchasing AFFF. It
has been recommended that the MIL SPEC is an appropriate standard for FAA certification
purposes [4].
Foam concentrates come in 6%,3%, and 1% products, being mixed with 94%,97% and
water
respectively. The foam solution that is formed generally contains the following:
99%
Water, 98%-99%
Surfactants (fluorosurfactants and hydrocarbon surfactants), 0.03%-0.45%
Butyl Carbitol (glycol ether), 0.5%-1.1%
Ethylene Glycol (not in all formulations), 0.34%41.60%
Urea (not in all formulations), 0.2%-0.4%
Xantham gum (in alcohol resistant formulations).
While mostly water, the actual firefighting solution is a mixture of a number of
chemicals. The potential environmental impacts and regulatory issues are many. An excellent
review of these issues is presented by Ruppert et al. [5] and Darwin et al [6]. The issue that has
caused the most significant problems, and occasionally has resulted in limiting the use of foam,
is the upsetting of a wastewater treatment plant. This effect is caused by the foaming, and as a
result efforts should be made to reduce the foaming of effluent solutions prior to release into the
treatment facility. This can be achieved by de-foaming or metering the solution. The generally
recommended disposal method is metering the solution into a wastewater treatment plant. 'If done
incorrectly this can result in the plant becoming dysfunctional and releasing improperly treated
sewage. The method of properly metering the solution can be found in the National Fire
Protection Association(NFPA) Standard for Low Expansion Foam(NFPA 11)[7].
More traditional environmental concerns exist with foam. The Biochemical and Chemical
Oxygen Demands(BOD/COD)are important in defining how well the concentrates biodegrade.
It may also be possible to remove oxygen from a watercourse too fast, resulting in a fish kill, but
in most releases this is unlikely. The acute toxicity of the foam is also a potential concern,
generally determined relative to aquatic animals. Much work was done in the 1990s to change
the solvents used in the formulations because some solvents were on the list of Hazardous Air
Pollutants and required release reporting to the U.S. Environmental Protection Agency(EPA)
when foam was used. Also, the act offoaming is an environmental issue and is regulated. While
these issues have existed for long time, a new issue has drawn attention.
The fluorochemical surfactants, the key ingredients that make foam so effective, have
long been known not to biodegrade completely. The fluorochemical surfactants used in foam
have a 6 to 10 carbon chain that is fully fluorinated and is impervious to biological, and most
chemical, assault. Recently, 3M discovered that the fluorochemical surfactants used in the Light
WaterTM products biodegrade to a compound that is also bioaccumulative and toxic. This
I Not contained in all agents

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combination of persistence, bioaccumulation, and toxicity(PBT) is considered a significant
environmental problem.

The PFOS Issue
On May 16, 2000 3M unexpectedly announced it was phasing out fluorocarbon surfactant
manufacturing which effected a number of product lines, including the Light Water"'
firefighting foams. The foams made up about 5% of the production of a business based on
fluorocarbon surfactants and similar chemistries that also included the ScotchGuardTM fabric
protectors, ScotchBanTM food wrapping paper treatments, and many other industrial uses. This
business represented about $300,000,000 worth of business, or slightly less than 2% of 3M's total
revenues.
The chemistries for these products are based on electrochemicalfluorination (ECF), a
method 3M uses to create heavily fluorinated molecules. 3M was the only major manufacturer in
the U.S. using this method, and one of only a few in the world. 3M had pioneered ECF in the
1950s and has had many product lines based on it over the years.
The chemical of interest from the ECF process is perfluorooctanesulfonyl fluoride
(POSF), C8F17S02F. When POSF, and the derived products, are biologically degraded the final
'chemistry is perfluorooctane sulfonate(PFOS), C8F17S03. This molecule is not believed to be
further degraded under any natural conditions except combustion. PFOS is persistent.
PFOS has been found to have a tendency to bioaccumulate. As part of 3M's regular
monitoring ofemployees, new and more sensitive methods of detection of PFOS in serum were
developed. The levels in relatively highly exposed workers are found to be in the few parts per
million. Studies using these methods have also found PFOS in small quantities, tens of parts per
billion, in the blood of the general U.S.- population [8]. These tests were conducted using pooled
samples from Multiple blood banks. Essentially, everyone in the U.S. may be carrying low levels
ofPFOS in their body.
Low levels of PFOS were also found in fish and birds'from various locations including
albatross on Midway Island in the Pacific. PFOS has a widespread presence and has been shown
to bioaccumulate.
Toxicology studies show that PFOS is absorbed orally and distributes primarily in serum
and the liver. Numerous repeat dose oral toxicity studies have been conducted with rats and
monkeys [9]. Toxic effects are seen at levels believed to be at least two orders of magnitude
higher then the exposed 3M workers, and four orders of magnitude higher then the general
population. These toxic effects are considered significant.
PFOS is considered to be a PBT, persistent-bioaccumulative-and toxic. The levels in the
general population are low and are not believed to present an imminent hazard. However,
concern is raised that with the continued production and release Of these compounds, eventual
adverse effects on people and the environment are possible. At the time of 3M's announcement

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of withdrawal from the market of the POSF derived products, they were in consultation/
negotiation with the EPA. Since that time, the EPA has proposed a Significant New Use Rule
(SNUR).
If this problem was only associated with PFOS and 3M's agents, despite some temporary
market chaos, it would not be particularly significant. 3M's withdrawal has drawn much
attention and this attention has spilled over to the other manufacturers agents. With 3M definitely
out of the business, and the focus turning to the other agents, this has the potential to be a serious
fire protection issue. The SNUR does specifically identify the other agents as the focus of
continued investigation and evaluation.

The Proposed SNUR
On October 18, 2000 the EPA published a proposed rule for PFOS [10]. The intent of the
proposed SNUR was to "shut the door" on any other manufacture or importation of the
chemicals 3M was voluntarily withdrawing. In the U. S., this would effectively end the
production and ultimately the release of chemicals that biodegrade to PFOS. The proposed
SNUR would have no effect on existing stocks of foam.
Along with the proposed SNUR, EPA accepted the voluntary phase-out schedule of the
chemicals. 3M proposed a graduated phase out, with very limited manufacturing continuing for
some applications into 2003. However, for the foam fluorosurfactants, 3M has stopped
production in the fall of 2001 and is merely taking orders from remaining stocks in the supply
chain.

The proposed SNUR is not a ban, rather it would require companies to file notice with
the EPA if they planned to manufacture or import the listed chemicals. EPA would look at the
proposed use and could grant, deny, or impose conditions on the intended use.
A public meeting was held on March 27, 2001.to address comments EPA received on the
proposed SNUR. All the significant comments were from PFOS users outside of fire protection.
The final rulemaking for the SNUR has not yet been issued as the comments and new
information on those uses is being examined by the EPA.
The Telomers
Of the many producers of firefighting foam, 3M was unique in at least two aspects. First,
they were the only company basic in the fluorochemicals that also produced foam concentrates;
all other manufacturers purchase the fluorochemical surfactants or intermediates from an outside
source, typically a major chemical company. Second, 3M's foams were the only ones using
fluorochemicals from the electrofluorination process; the others all used fluorochemical
surfactants derived from the telomerization process.

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The telomerization process produces a molecule for surfactants distinctly different then
that produced by electrofluorination. The product from the telomerization process predominantly
used for foam is perfluorohexyl iodide, C6F131 [11]. Further chemistry is performed on this
molecule by replacing the iodide with various groups to get the desired surfactant properties.
This chemistry is distinctly different then the PFOS chemistry and does not biodegrade down to
the PFOS molecule.
The telomer based surfactants do biodegrade down to a molecule that contains the highly
fluorinated carbon chain and this molecule is not expected to further biodegrade. But what
molecule this is has not been established and is currently a subject of contention. Two
possibilities apparentlyexist; the molecules biodegrade down to perfluorohexanoic acid,
C5FIICOOH, or the biodegradation product is unknown.
Perfluorohexanoic acid is a shorter chain homologue of perfluorooctanoic acid (PFOA), Afr
C7F17C001-1. There is not a lot known about perfluorohexanoic acid, but PFOA is a commercial
chemical with a major use as a processing aid in manufacturing. What is known is that different
chain length homologues have many similar properties.
PFOA was also found in some of the pooled serum samples 3M was testing for PFOS,
but at even lower levels of a few parts per billion. The bioaccumulation potential of PFOA has
not been examined as thoroughly as PFOS and it is not yet known if the presence of PFOA in
some of the serum samples represents a wider problem.
If the telomer based surfactants do biodegrade to the PFOA homologues, and if PFOA is
confirmed to bioaccumulate, then the telomers may become the focus of regulatory efforts. The
EPA has repeatedly indicated that the PFOA and the telomers are subjects of interest to them.
EPA is currently performing a hazard assessment on PFOA with the results expected in early
2002. This hazard assessment was expected in June, but due to additional information being
made available and the need to have it reviewed at high levels within the EPA, it has been
delayed.
Environmental and toxicological information on the telomers is being voluntarily
submitted by the manufacturers to the EPA. In response, five of the producers (Asahi Glass,
Atofina, Clariant, Daikin, and DuPont) have formed the Telomer Research Program (TRP)
Group and presented a research program to the EPA in October of2000. The multi-year multimillion dollar study is expected to produce definitive results on the fate of the telomers and
assess the toxicological hazards.
The Current Situation
The largest U.S. supplier of firefighting foam for the aviation industry has ceased
production. Other manufacturers can supply foam with similar or better fire extinguishment
performance. All of the othef foams containing fluorocarbon surfactants come from the telomer
manufacturing process. While these have not been shown to biodegrade to a chemical that
bioaccumulates and is toxic (it will however be persistent), there is much regulatory interest and

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ongoing research. Aviation industry users must be prepared to request and understand the listings
and approvals of any new agent being offered to insure its performance will mect their
requirements. To date, no non-fluorocarbon containing foam has been able to demonstrate the
performance that is achieved by high quality fluorosurfactant based foams [12].
Users who currently use 3M AFFF for CFR applications may have questions regarding
purchase offoam as stocks of existing foam are depleted through normal or emergency use. This
should not be a significant problem. The earlier survey of major airports [1] indicated that the
majority used the MIL SPEC as the procurement specification when purchasing foam. Since the
MIL SPEC requires compatibility between all agents on the Qualified Products List(QPL), users
can simply purchase another product from the QPL. All others are the telomer-based AFFFs.
Users who do not use the MIL SPEC should verify compatibility before mixing AFFFs from
different vendors.
The relatively small quantity oftelomer chemicals used in foam may not prevent
potential regulation by the EPA. The EPA has identified the release of surfactants in foam (and
other products) to the water as one of the possible routes of human exposure for PFOS [131
While the precise exposure route(s) is not known, releases to watercourses and subsequent
ingestion are being investigated. Also being investigated is intake from food wrapped with
treated paper and inhalation from airborne sources.
The historical environmental issues with foam have always called for a high standard of
care with its use, whether for actual fire fighting, training, or system discharge testing. The
additional concern over the environmental fate and affects of the fluorocarbon surfactants should
be considered by users when assessing the responsible storage, handling and discharge of foam.
Even if the disposal guidelines recommended by most foam manufactures are followed (e.g.,
metered input to a wastewater treatment plant), this will not change the fluorocarbon surfactant
impact as they pass through the plant into the watercourse.
The recognition of the potential environmental impact of the fluorocarbon surfactants and
their uncertain future has led to calls for research on replacement chemicals and technologies.
The EPA, in a presentation to the U.S. Department of Defense Fire and Emergency Services
Workgroup, has noted that "a program to seek, test, and consider long-range alternatives to
current fluorosurfactant-based AFFF would be prudent" [14].
Potential Impact on Aviation CFR
If current fluorochemical-based foams become unavailable, there are two potential
approaches for addressing the needs of the aviation industry. The first is to develop new agents
with similar performance. Alternatively, agents having lower performance could be used,
recognizing that greater quantities would be required for protection equivalent to AFFF.
In anticipation of increasing restrictions on production of AFFF, the Naval Research
Laboratory(NRL) performed a review of the different approaches that might be used to
develop
alternatives [15]. Two fundamental approaches were. identified: One approach is to identify

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alternative chemicals and formulate novel foam concentrates (i.e., the "chemical approach").
These novel foam concentrates would first be screened to see if they form an aqueous film on
fuel surfaces. They might also be fire tested at a relatively small scale. This approach assumes
that a positive,spreading coefficient (i.e., the formation of a film) on a hydrocarbon fuel is
necessary for a candidate agent to have similar if not equal fire extinguishment and burnback
performance as AFFF.
An alternative approach, which would be pursued in parallel with efforts to identify new
chemicals, is designated as "fire extinguishment fundamentals." This approach assumes that
chemical derivatives that combine both desirable firefighting and environmental characteristics
are not readily available or identifiable. The contention is that a lack of a fundamental theoretical
understanding of foam spreading and extinguishment mechanisms limits the ability to investigate
novel concepts/formulations. This approach relies on the development of a foam spreading
extinguishment model to predict agent performance. Small-scale apparatus would be used in
support of this model. Having verified the extinguishment model, approaches that provide the
required physiochemical properties could be investigated. This could lead to synthesis of agents
that do not rely on the surface-tension reduction characteristics (for which fluorosurfactant
chemicals are vital).
Since the development of an entirely new agent is considered a moderate-to-high
technical risk both approaches would be pursued as there is much technical cross-over in both
efforts. Currently, no near-term substitute agent has been identified which has performance equal
to AFFF.
The alternative would be to use existing protein-based foams. The FAA, NFPA, and
ICAO recognize the use of protein-based foams for CFR use. Where protein foam is used as
substitute for AFFF, the FAA requires the volume of water carried by CFR vehicles to be
increased.by roughly fifty percent [16]. Consider the situation where an FAA Index E airport is
required to have CFR vehicles with a total of6,000 gallons of AFFF discharged at a total rate of
1,200 gallons per minute (gpm). If protein foam was used, the CFR vehicles would have to have
a capacity of9,000 gallons and a total discharge rate of 1,800 gpm. If 2,500 gallon/500 gpm CFR
vehicles are used, the number of required vehicles would have to be increased from three to four.
The increased equipment requirements become more exaggerated if NFPA 403
guidelines [17] are used by an airport. For the same FAA Index E(NFPA Category 9) airport,
9,570 gallons of AFFF at 1,200 gpm is recommended by NFPA. Approximately 13,000 gallons
of foam at about 3,500 gpm is the protein-based foam equivalent. In this case, the number of
required vehicles would be increased from four to six or seven.
There are also practical considerations in converting CFR vehicles from AFFF to protein
foam. Proportioning systems would have to be modified to account for higher flow rates and
differences in foam concentrate viscosity. Non-air aspirated foam discharge nozzles would have
to be replaced with air-aspirating nozzle.
If the current fluorochemical based foams become unavailable, and new agents with
similar performance arc not developed, airport operators are likely to see a large increase in the

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cost of protection if they are required to use currently available protein-based foam. It should be
emphasized that this is not expected in the near term.

Future Developments
The most significant near-term future developments related to AFFF environmental
issues are the PFOA hazard assessment and the definitive determination of the biodegradation
product(s) of the tclomer based surfactants. If the PFOA hazard assessment turns out to not
indicate significant environmental concerns, then perhaps the fluorocarbon surfactants will not
be regulated or controlled.
If the fluorocarbon surfactants do not biodegrade to the homologues of PFOA, then the
actual biodegradation products will need to be defined and studied. This process would likely
take several years. In the interim, direct regulatory action would be unlikely.
If the telomer surfactants are found to biodegrade to the PFOA homologues, future
regulatory action n-lay Occur. The degree of regulation would be dependent on the PFOA hazard
assessment. The regulations could be developed under the rules of the Toxic Substances Control
Act(TSCA). TSCA uses an "unreasonable risk" standard in an attempt to balance hazard,
exposure, benefits, costs, and availability of alternatives at the time of the proposal. The actions
that could be taken include: testing requirements (Section 4); SNURs and new chemical reviews
(Section 5); manufacturing, use and disposal rules (Section 6); and, information submittals
(Section 8).
Invoking Section 6 and developing use and disposal rules would have the most direct and
immediate impact on the fire protection community. Because the use offoam is almost always
emissive and the surfactants end up in the environment, it may be relatively high on the list of
regulatory issues. In general, the EPA prefers to negotiate with industry and have them take
voluntary action rather then regulate (i.e. 3M and PFOS). The regulatory process, if effectively
contested by industry, can take several years and result in significant costs to both parties.
Unless he biodegradation products pose an immediate risk to human health or the
environment, any regulatory activity is unlikely to affect existing stocks offoam. Rather,
regulators will likely focus on future production and use. The objective would be to stop the
production, and hence cap the quantity in the environment, at a level not believed to be
hazardous. The logistics and costs of trying to collect and destroy (by incineration) the existing
stocks would be prohibitive.
A potential option for the fire protection community would be to ask for exemptions from
regulations on the basis that the increased risk from loss of life, major property damage, and
disruption of portions of the economy outweigh the risks from continued use of the
fluorosurfactant based foams. This strategy would probably only be effective if it was very
specific: AFFF at airports for crash fire rescue, aircraft carrier flight deck firefighting,
extinguishment of large storage tank fires, etc.

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The percentage offoam production used to fight fires is relatively low, estimated to be
5% to 10%, but is not validated with data. The other 90% or so is used for training, system
testing, accidental discharge, replacement of contaminated or obsolete stock, or stored in new
systems. While an exemption may be made for actual firefighting it is highly unlikely to be
acceptable for training, testing, accidental release etc. The fire protection community may need
to develop technologies and code's of practice to reduce these releases to the absolute minimum
feasible. This is both to enhance the position relative to any future regulations but also for good
stewardship of the environment. Some manufacturers already use alternative, non-foaming
agents for system testing, as well as for FM and UL approvals.
Conclusions
The fluorocarbon surfactants used in foam are being scrutinized because of concern over
their ultimate environmental fate. The fluorocarbon surfactants used by 3M biodegrade to
PFOS, a chemical that is persistent, bioaccumulates and is toxic. 3M has ceased manufacturing
these chemicals. Other foam manufacturers use fluorocarbon surfactants from the telomerization
process and these surfactants are currently being scrutinized by the EPA. The biodegradation
products of the telomer chemistries are known to be persistent and are being tested and examined
for their bioaccumulation potential and toxicity.
Currently, there are no regulations limiting the use of fluorocarbon based foam because
of the biodegradation products concern. Even though the 3M foams are no longer in production,
foams which provide equivalent protection are available from a number ofother manufacturers.
Users should be aware of these environmental issues when assessing the responsible storage,
handling, and discharge of foam. If the telomer-derived surfactants biodegrade to a chemical that
is a PBT, then product withdrawals and regulation of the existing foams may occur.
While replacement agents that do not contain fluorocarbon surfactants will become more
available, these agents do not currently have the same performance as existing foams. The lack
of capability could be compensated for by increased agent volumes and applications rates. While
this may provide an equivalent level of performance, it will be at a substantially increased cost.
Recommendations
In the near-term, the aviation industry should closely monitor the activities of EPA
related to the PFOA and teloiner assessments. These activities are having an impact on foam fire
protection. Already we are seeing proposals from vendors of"environmentally friendly" foams to
accept their products for aviation fire protection. NFPA 403 requires that agents uscd at the
AFFF flow rate and agent quantity meet the MIL SPEC performance criteria. This technical
position was validated and recommended for adoption by FAA in 1994 [4]. Yet, to date, this
recommendation has not been implemented. A recent performance analysis of foam agents
required to combat aviation-related fuel fire hazards reaffirms that the MIL SPEC provides an
appropriate level of performance [18]. If alternative foams are to be evaluated, a baseline of

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performance needs to be established and in place. FAA should adopt the MIL SPEC performance
for .AFFF as previously recommended.
Proponents of alternative foam test methods, particularly international standards, which
are less restrictive than the MIL SPEC, argue that many U.S. airports use protein-based foams.
This contradicts the findings of the 1990 study which indicated that all of the 24 largest U.S.
airports in the U.S. use AFFF [I]. It would be useful to update this study to determine if this is
still accurate. At the same time, a survey of typical CFR foam capacity, discharge and pumping
equipment could be performed to determine the impact of a potential transition to protein foams
or foams having similar performance characteristics. It would be in the interest of FAA and
airports to have this information available should further restrictions be proposed on the use of
AFFF.
Just as the fire extinguishment and burnback performance of foam needs to be quantified
(e.g., by adoption of MIL SPEC criteria), so should acceptable environmental criteria and
associated test methods. It is clear that environmental criteria in the MIL SPEC needs to be
updated to reflect current concerns. Vendors are already advertising environmental improvement
through the reduction offluorosurfactant content. It is unclear to what extent this mitigates
environmental impact in terms of the EPA assessments. For example, efforts have been proposed
to develop screening models that predict bioconcentation of chemicals in organisms. These
methods could then be adopted in appropriate foam specifications. The aviation industry should
support such efforts.
As noted, the development of a non-fluorosurfactant based foam will be a challenging
endeavor. There is an opportunity to advance the science of fire protection in an effort to identify
new, environmentally improved agents. The aviation industry could take a leadership role in this
effort; alternately, the FAA and industry should support efforts by the U.S. military and others in
the international community in these efforts.
References
1.

Scheffey, J.L., Darwin, R.L., Leonard, J.T., Fulper, C.R., Ouellette, R.I., and Siegmann,
C.W.,"A Comparative Analysis of Film Forming Fluoro-protein Foam(FFFP)and
Aqueous Film Forming Foam (AFFF)for Aircraft Rescue and Fire Fighting Services,"
Hughes Associates, Inc. Report 2108-A01-90 for the NFPA Aviation .Committee, June
1990.

2.

UL 162, "Standard for Foam Equipment and Liquid Concentrates, "Underwriters
Laboratories Inc., Northbrook, IL, Sixth Edition, 1994.

3.

Military Specification,"Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF)
Liquid Concentrate, for Fresh and Seawater," MIL-F-24385F, 7 January 1992.

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4.

Scheffey, J.L., and Wright, J.A., "Analysis of Test Criteria for Specifying Foam
Firefighting Agents for Aircraft Rescue and Firefighting," FAA Technical Report,
DOT/FAA/CT-94/04, Atlantic City, NJ, August 1994.

5.

Ruppert, W. H., Wakelin, A. J., Verdonik, D. P., Scheffey, J. L., Gott, J. E., and Simone,
J., "Development of Policy and Design Criteria for Activation of AFFF Fire Suppression
Systems in Naval Facilities Using a Risk-Based Approach," Final Report 5515, Hughes
Associates, Inc., December 12, 2000.

6.

Darwin, R.L., Ottman, RE., Norman, E.C., Gott, J.E., and Hanauska, C.P.,"Foam and
the Environment: A Delicate Balance," Fire Journal, Vol.89, No.3(May/June 1995), pp.
67-73.

7.

NFPA 11, "Standard for Low-Expansion Foam," National Fire Protection Association,
Quincy, MA, 1998 Edition.

8.

3M,"Perfluorooctane Sulfonate: Current Summary of Human Sera, Health and
Toxicology Data," 3M, St. Paul, MN,January 21, 1999.

9.

3M,"Sulfonated Pcrfluorocarbons in the Environment: Sources, Dispersion, Fate and
Effects," 3M, St. Paul, MN, March 1, 2000.

10.

U. S. EPA,"Perfluorooctyl Sutfanates; Proposed Significant New Use Rule," Federal
Register, October 18, 2000.

11.

Kleiner, Eduard, Personal Correspondence, Dynax,'Pound Ridge, NY, May 25, 2001.

12.

Scheffey, J.L., Darwin, R.L., and Leonard, J.T., "Evaluation of Firefighting Foams for
Aviation Fire Protection," Fire Technology, Third Quarter, 31 (3),.August 1995.

13.

Leczynski, B.,"EPA Activities/Issues on Fluorosurfactants & AFFF," presentation to the
AFFF Manufacturers and Users Group, May 31, 2001.

14.

Dominick, M. F.,"EPA Activities/Issues on Fluorosurfactants," presentation to the DoD
Fire and Emergency Services Workgroup, January 23-24, 2001.

IS.

Scheffey, J. L., Hanauska, C. P., Burns, R. E., and Williams, F. W., "Status Report on the
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