Firefighters in foam blanket (Buncefield): resistance to fuel pick-up delivered by fluorotelomer-based foams help make these types of situations safe for firefighters by preventing sudden flashbacks. Picture courtesy of Angus Fire.

Australian foam forum – a point of view

Published:  09 December, 2011

Mike Willson of Willson Consulting (Australia) attended the 1st National Foam Forum & Workshop in Adelaide. He outlines his reactions to some of the many issues raised during the conference.

Mike’s article has been reviewed by Tom Cortina, of the US-based lobby group Fire Fighting Foam Coalition, which aims to provide information on the environmental impact of AFFF agents and the fluorosurfactants they contain. The article has also been reviewed by Fire Fighting Foam Coalition member Steve Korzeniowski of Du Pont USA, who also presented at the Forum.

Clear ‘position paper’ objective

Unlike most conferences, the First National Foam Forum declared an objective from the start, which was: ‘To produce a position paper for foam procurement’.

It was clearly explained that the intention was to begin a process of developing and implementing a sound, secure and prudent procurement policy in a co-operative atmosphere of sharing and learning. This was being managed by a Government organisation; delivered by CRC Care – a powerful partnership of scientific, industry and Government organisations, set up to devise new ways of dealing with and preventing contamination of soil, water and air. To me this seemed slightly at odds when there was a single ‘environment friendly’ foam producer as sponsor of the event, and formulating the policy, so any prospective purchaser using this future policy would clearly need to carry out their own due diligence to establish the facts and satisfy themselves they were taking the correct unbiased approach. Wouldn’t it be better to have a balanced team working on it to ensure a more robust and even handed resulting document?

As a stakeholder representative in the UK Department of the Environment’s world-leading Risk Reduction Strategy for PFOS, I was privileged to be part of such a diverse stakeholder engagement approach, which worked extremely well. It made me wonder why such a diverse stakeholder format had not been followed here, and I was not alone in thinking that any draft policy document should be passed around such a delegate group, providing a ‘ready-made’ well informed, diverse and interested ‘sub-set’ of stakeholders on which to build. Only time will tell whether this will happen in Australia, but at least an important first step was taken when all attendees were encouraged to add their names to a circulated list which has subsequently been forwarded to all delegates.

Whilst this short forum could only ever expect to set some broad parameters (eg headings requiring further work), I felt it was right to try to clarify and refine these first.

Identifying gaps

For me, an important turning point occurred when the forum focussed on gaps in our current knowledge – an important requirement before any meaningful policy could be developed. At this point the event seemed to have the potential to become a genuine attempt to lay down some clear, fair and possibly unbiased guidelines that could be of significant benefit, not only to Australia, but also the world.

Dr Marion Healy, Director of the National Industrial Chemicals Notification and Assessment Scheme (NICNAS), operated under the Australian Government’s Department of Health and Ageing, presented a very balanced and frank approach. It became clear her department is working very hard to scrutinise new chemicals, and develop a framework of controls for existing less desirable fluorochemicals like PFOS, which is proven persistent, bioaccumulative and toxic (PBT).

Similar to US and European regulators, NICNAS seems conscious of the need to separate PBT chemicals (deserving tight controls) from PFOS-free telomer based fluorosurfactant foam concentrates, which was to be applauded, since it is often easier to restrict the use of everything in a broad category like fluorochemicals to the detriment of all existing and potential users. These concentrates are delivering major performance benefits in both fast flammable liquid fire control, and personnel safety for firefighters using them – often in difficult and dangerous situations.

Update on global regulatory environment

Before the main forum discussion, the conference was split into three sessions. Updates were provided by Government and regulators on the global regulatory environment, as well as by fluorine free, and fluorinated, foam supporters.

Germany is perhaps taking the most precautionary approach, having already set threshold levels in 2010 for perfluorinated carbon compounds (PFCs) in drinking water and sewage sludge. Germany, explained Annegret Biegel-Engler (German Federal Environment Agency, UBA), is studying the build up of a range of PFCs in soil, groundwater and vegetables, where the highest concentrations have been found in beans and celery.

Concerns over long range transport into remote areas and persistence exist, following the European Union (EU) regulatory ban on usage and storage of PFOS based chemicals and their pre-cursors.

In the European Union after June 2011, PFOS-based firefighting chemicals must be disposed of by high temperature incineration. No fluorinated foams should be used in training, and only the smallest quantities should be used in emergencies. As was heard later in the Forum surprisingly from Ted Schaffer, who’s research has shown that AFFF foams containing telomer-based fluorocarbon surfactants require up to three times less concentrate (used on a given fire scenario) than alternative fluorine-free products, so significantly less concentrate and water resources are used, resulting in considerably less fire water run-off potentially being collected and processed through waste water treatment.

Attendees heard about the 2009 Stockholm Convention placing strict international regulation on the use of PFOS. Outside the EU, I wondered how many of the signatories to the Stockholm convention are implementing its recommendations and have policies in place to restrict the use of PFOS? It is known that Australia, amongst others, has not done so yet.

Dr Jimmy Seow from the Western Australian Department of Environment and Conservation commented on the US Environmental Protection Agency has developed its PFOA stewardship program which – although voluntary – has been adopted by several major fluorochemical producers including Du Pont. They are ahead of schedule after achieving over 95% reductions by 2010, and it is expected Du Pont will achieve complete phase out ahead of the 2015 target date. Canada legislated in 2010 for the management of PFOA and its pre-cursors, also with the intention of future phase out.

Norway and Germany are proposing restrictions on PFOA, particularly in consumer products, to take effect from 2016. My question is, why so little concerted action from the United Nations in co-ordinating these approaches? This could potentially help restrict the use of PBT substances such as PFOS more quickly, and hence reduce the likelihood of build up in the environment.

Currently in Australia there is no written policy on the use of fire fighting foams, except for the Country Fire Authority Victoria, which requires Class A foams and wetting agents to be at least 60% biodegradable within 28 days. Victoria’s current Class A usage is nominally 100% biodegradable in 14-30 days and wetting agents 80% biodegradable within three days. The Western Australian (WA) Government through its Department of Environment and Conservation is taking up this challenge with what I believe is a more holistic and balanced approach.

WA recognises that no environmentally benign foam exists. All foams have some impact on the environment, whether by ecotoxicity, persistence, biodegradation or bioaccumulation. This position raised more questions among attendees: why focus exclusively on after-use environmental impact? Why not consider a product’s fire performance and efficiency? What about fire fighter safety; minimised water and agent use; impacts of no action – so-called ‘let it burn’ strategies; incident escalation; aerial pollution from smoke; evacuation costs; and health impacts of particulate pollution on those with respiratory difficulties?

These issues were well answered by Dr Seow from WA, who is interested in evaluating a holistic approach with consideration of all these factors, and more.

He confirmed that looking only at environmental consequences may not give the best or truest answers. One must also investigate product fire performance aspects, fire fighter safety issues, increased pollution potential from oil emulsification, foam containment, capture and disposal methods, as well as soil and water remediation possibilities.

He recognised the large performance and impact variations between foam concentrates. It was encouraging to hear that consideration is also being given to the modern natural protein fluorotelomer surfactant based products like AR-FFFP (alcohol resistant film forming fluoroprotein) foams, without the oil emulsifying effects of detergents.

In my opinion strong promoters of current fluorine-free foam (F3) products missed several major opportunities to prove their points, as they just covered old ground, repeating old research and bringing no new testing, case studies, product improvements, or extra information to the audience, and which for me was frankly disappointing.

Class A v Class B fluorine-free foams (F3s)

To my mind it felt as if supporters of F3 foams were just trying to show that class B F3s were superior to class A F3s on flammable liquids (which they are), while also confirming that Class B F3s only lasted 30% as long as a Mil F spec AFFF on a given fire (also true). Logic would then follow that presumably it required three times as much concentrate, water resources, duration and fire water run-off, to deal with a given fire.

A valid concern expressed was that firefighters could possibly assume tactics and equipment would remain unchanged when purchasing Class B F3 foam. With AFFFs currently using non-aspirating discharge equipment, the question was; would the performance of F3 performance fall off dramatically or – worse still – perhaps fail to work when used non-aspirated? And this begged the question whether without non-aspirated film-forming ability, F3 foams should be labelled ‘for use with aspirating foam nozzles only’?

Without wanting to appear to pick holes, one interesting supposed ‘fact’ that emerged was that class A foams account for approximately 95% of foam applications used on fires. If this is indeed factual, the time investment into the impact of class B foam seems slightly disproportionate. Shouldn’t then at least an equal amount of effort be made to reduce the toxicity impacts of class A foams, which are the most widely dispersed – often in the most sensitive environments – by restricting their use too?

It should be noted that even ‘environmentally friendly’ F3 foams are generally categorised R51/53 toxic, with long term adverse effects to the environment. One should also bear in mind that this classification refers to a class B F3 foam which may be discharged at between 3 and 60 times higher strength than Class A foams used for forest and bush fire fighting.

Aviation implications

It was interesting to hear from Craig Barnes of the Government-owned Airservices Australia, which operates air traffic and other essential airport services including aircraft rescue and fire fighting (ARFF), at all 39 airports around Australia. This organisation has recently transitioned from AFFF 6% to a 6% F3 foam, and it is implementing this change throughout the nation.

It is a detailed and time consuming change-out process, ensuring no residual contamination in equipment, trucks, and even PPE gear. It was very surprising to hear that these emergency response personnel see their primary role as controlling fires and evacuating personnel, not extinguishing them! Does this meet a perceived operational objective for fast response to maximise the opportunity to save life?

To me this conflicts with the general perception of a fast response with safe and rapid fire extinction, to deliver maximised safety for firefighters, crew and escaping passengers, ensuring the maximum opportunity to save lives. Are other ARFF services adopting a similar approach?

Australia seems to have shifted dramatically in recent years, from requiring its aviation foams to meet one of the toughest standards in the world – above Mil F Spec level – to now perhaps barely meeting the ICAO Level B standard. Yet planes have become larger, more complex, more frequent, and probably more volatile, and I wondered whether this was sensible.

Supposing a large wide-bodied A380 Airbus crashed at Sydney airport, would this operational objective mean the F3 foam now in service – and which in my opinion has no safety margin – would not be expected to put the fire out? This means lives could be put at risk from potential flashbacks and sudden re-involvement because the fire is not extinguished.

I feel it is important to point out that Mil F-approved AFFFs have to extinguish the same 28ft2 fire tray at half strength, within 45 seconds, in recognition that only one fire truck may be able to reach the incident quickly, or a nozzle could become partly blocked, or some unexpected error could occur, restricting the foam application rate to the fire.

This approach builds in a safety factor so the foam can still safely get the job done, under less than ideal circumstances, and I wondered whether the same could be said of F3 foams in real-life fire situations?

Another eminent aviation specialist Bernard Valois spoke well of individual risk assessment requirements that address the different needs of specific applications, which may each require a different solution. Should we be restricting ourselves from the best answers now, because we fear what may or may not happen in years to come? Of course alternative approaches and solutions must be sought, but surely we do not have to grasp the first possible answer that comes along, when a robust solution is not being delivered?

On the issue of minimising the resultant spillage of foam during regular testing, one delegate confirmed this had been overcome in Scotland. Here, an additional small colour-coded lockable foam tank of natural protein training foam is used, which is designed to mimic the viscosity of the operational film forming fluoroprotein (FFFP) foam in the main vehicle tank. This is used for training and regular calibration checks of the induction devices and foam monitor trajectories. Witness-tested by the UK Civil Aviation Authority, this F3 training foam has been accepted as accurate to within 0.2% induction accuracy of the front line fluorinated foam, which allows these airports to train and complete checks when there is no fire emergency, yet they retain the high performance fluorinated foam benefits for maximum operational efficiency.

Are telomer-based fluorosurfactant foams as bad as some make out?

A major fluorinated foam supplier and a major fluorotelomer surfactant manufacturer were given the opportunity to speak, but it seemed the five F3 presentations unjustly tried to outweigh these two excellent presentations helping to understand how we can continue using fluorinated foam products to provide the fastest and safest conditions for firefighters, while minimising their impacts in the environment.

Nevertheless the approach taken by both sides of the argument was very positive. A strong realistic approach was adopted by Brett Staines of Chubb Australia, recognising that all foams have an environmental impact. He helped delegates better understand what the trade-off is: How do we maximise the benefits from using any foam as sparingly as possible? These benefits should not be forgotten, and include; reduced loss of life, fast and efficient extinction, reduced atmospheric pollution and toxic gas releases, minimised incident escalation and – vitally important – firefighter safety.

A four-level hierarchy of risk reduction was introduced by Brett and taken up in the later forum session, from elimination by design; minimisation by design; through use of appropriate engineered safeguards; and use of administrative controls (eg safe work practices).

I believe a simple substitution of fluorine-containing foam by fluorine-free foam will do little (or nothing) to eliminate environmental impacts. It requires actions like improved containment, bunding of foam and fuel storage tanks, better waste water collection, oil interceptors, spill containment kits, disposal through waste water treatment, plus improved operational procedures and work practices, to really make a difference. We should be considering these alternative, possibly better, approaches to minimising our environmental impacts, at least until better second-generation F3 foams are developed that address some of the problems associated with current offerings. The highest levels of fire performance, less aquatic toxicity and  more biodegradability means less fluorotelomer surfactant based foam is used, of a less aggressive type of foam, which is then subjected to improved management of its collection and disposal.

Equally positive was the presentation by Dr Stephen Korzeniowski (DuPont USA) on research his team have conducted to purify fire water run-off after the fuel separator. This showed effectiveness with both fluorinated and F3 foams. This pilot system used a 4-part separation: electrocoagulation; flocculent segregation; reverse osmosis treatment and final activated carbon polishing. This proved capable of reducing initial fluorosurfactant concentrations of 115ppm (parts per million) in the run-off to 31ppm after flocculent segregation in just 30 minutes, and on down to 10-16 ppb (parts per billion) after reverse osmosis and activated carbon polishing, in a total time of around two hours. It was equally effective at removing hydrocarbon surfactants from F3 foams and the main foaming agent in AFFFs.

While the initial equipment cost is currently high, the operating costs of effluent treatment seems remarkably reasonable at around 1US$/m3, pointing a way forward to possibly having the best of both worlds: the most effective fluorotelomer surfactant based firefighting foams + fire water run-off collected and effectively treated  = barely detected perfluorinated compounds in the treated water released back into the environment, minimal aquatic toxicity and minimal environmental impacts.

Position paper discussion

A risk and impact assessment approach was generally favoured by delegates for adoption to cover class A and B foams, with possible essential uses in certain areas. Acceptance of different foam suitability for different hazards, plus improving containment profiles would help justify some foam types over others and maintain fluorotelomer based foams for the tougher assignments. A desire to establish what is fit for purpose, a review of containment, mitigation measures and disposal options, was also agreed. A number of gaps in our knowledge were highlighted, that would need answers to better inform the resulting position. These included:

•            What is or should be the right framework to use? Elements from both environmental impact assessment and hazard management risk assessment processes could help inform the process of developing a framework.

•            How clean is clean? What are acceptable and safe guidelines for contamination of water and soil quality?

•            How do we define trade waste acceptance criteria? Who is the polluter?

•            How do we evaluate environmental sensitivity?

•            Who has or should have an approval function  with enforceable legislative powers?

•            Do we have incinerators capable of handling PFOS disposal at 1,100°C? If so, where?

•            Do end-users have consistent emergency response plans, and are they adequate?

•            Perhaps a national emergency response guidance document could give helpful advice on how to manage fire fighting foams in future?

•            How much information, advice and outreach training should be provided?

•            How effective are F3s on large scale fires, and particularly fuel in depth fires?

•            How do changes in foam quality affect and limit F3 fire performance?

It also begs the following questions of; how safe is safe? Are we prepared to put our firefighters into dangerous situations without always providing them with the best tools for the job? How do we explain to their relatives when the worst happens that a better answer was available, but was not chosen for use in this situation?

Conclusion

Despite lacking answers to many of these important questions, both the organiser Dr Roger Klein, and the chair of the main discussion Dr Marion Healy, are to be congratulated on generating such a positive atmosphere and contributing to this important debate, with what was a good conference. We hope it will move forward and develop a meaningful policy document, with as much diverse stakeholder input and rigorous questioning, as possible.

Any conference generating more questions than answers it delivers has to be stimulating, thought-provoking and a valuable contribution to the debate. This one scored highly in that regard. Let’s hope we see resulting actions.

  • Operation Florian

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