Firefighting foams have long been used to extinguish even the most challenging fires. However, years of research have led scientists, environmentalists, and governing bodies to realize that one of these types of foams, aqueous film-forming foam (AFFF), can pose serious environmental and health hazards.
These hazards are due to AFFF containing per- and poly-fluoroalkyl substances (PFAS). You may have heard about the dangers of PFAS, as it’s a topic that’s becoming increasingly prevalent in nationwide news. If you haven’t, the general consensus is that PFAS are dangerous because they don’t degrade or break down — making them extremely pervasive in the environment and in the human body.
All that said, maintaining extreme caution and strict control when using AFFF to fight fires is critical in the effort to keep our planet and people safe. One important aspect of this is knowing how to dispose of the substance properly. We’ll discuss some of the current requirements and best practices for AFFF disposal below.
AFFF Disposal Requirements & Best Practices
The developments in AFFF and PFAS research are rapidly transforming the fire protection industry — so much so that federal, state, and local government agencies are having trouble keeping up and passing legislation to reflect new findings. The United States Environmental Protection Agency (EPA) and other American legislative bodies have only begun to take action.
All this goes to say that AFFF disposal requirements heavily depend on where you live and what legislation your governing authority has or hasn’t enacted. Every state has its own rules and regulations. However, there are some general AFFF collection and disposal guidelines to follow to ensure the highest possible level of environmental and human safety.
The AFFF Containment Process
The most important thing to remember about managing AFFF is to never release it directly into the environment. You should always work to ensure all foam and firewater runoff is properly contained after discharge. This can heavily minimize the harmful effects of the substance.
Here are some best practices for AFFF containment:
- Develop a comprehensive firewater runoff collection plan for any regularly scheduled discharges (inspections, tests, maintenance)
- Develop an emergency plan for dealing with unplanned releases of foam (fires or system malfunctions)
- Install onsite primary and secondary containment systems
- Block all nearby sewer drains
- Build temporary dikes or booms
These measures are important to take because once you effectively contain AFFF, you can properly transport and dispose of it as well. Which brings us to the next step:
The AFFF Disposal Process
You shouldn’t attempt to dispose of AFFF on your own. Instead, you should transport your contained AFFF to an accredited disposal company.
The most common method of AFFF disposal is high-temperature incineration. This heats the substance up to at least 1000°C, with a minimum residence time of two seconds. An accredited disposal company has the knowledge, resources, and preventative measures to complete this process safely and effectively.
AFFF Containment & Disposal in Specific Discharge Situations
Besides typical firefighting operations, the discharge of AFFF is most likely to be the result of one of these scenarios: training or testing. Below, we’ll walk through each of these scenarios and provide tips on AFFF containment and disposal best practices for each of them.
AFFF Containment & Disposal During Training
In some states, it’s prohibited to use AFFF for any training procedures. This is because they’ve deemed AFFF so harmful that it’s only allowed to be discharged in high-risk, pertinent situations.
Fortunately, there are specifically designed training foams available that simulate AFFF for training purposes, but don’t contain PFAS. These foams are biodegradable, have minimal environmental impact, and can be safely treated at your local wastewater treatment plant. It’s recommended that you use these foams for training, even if the use of AFFF hasn’t been banned in your state.
AFFF Containment & Disposal During Equipment or System Testing
As with any other fire suppression system, AFFF equipment needs to be regularly inspected, tested, and maintained to ensure it functions properly in the event of a fire. There are two main types of tests conducted on AFFF systems:
- Acceptance tests, which are conducted to ensure successful system installation
- Maintenance tests, which are conducted regularly to ensure the system stays in good condition
During both of these tests, it’s important to only discharge a small amount of the substance — just the amount you need to ensure the correct concentration of foam in the foam-water solution. This foam should then be directed to a controlled location using foam-water test ports in the piping system and a portable tank. Then, the tank can be easily transported to an accredited disposal company for disposal.
For the remainder of your test, you should close the foam injection valves and conduct the test using only water.
New Legislation Regarding AFFF Disposal
Around 33 states have enacted or proposed regulations regarding PFAS in firefighting foams and equipment. Most of these regulations can be categorized into one of these four topics:
- Discharge or use restrictions
- Disposal, storage, inventory, or “take-back” provisions
- Notification and reporting
- Limitations on PPE
While each state has different laws, it’s clear to see that the country as a whole is recognizing and responding to the effects of PFAS in AFFF. The National Fire Protection Agency (NFPA) is also keeping up with national guidelines and trends, reviewing their standards on foam health, safety, and environmental issues.
For the fire protection industry and all facilities that currently employ an AFFF fire suppression system, this means that change is coming. By listening to professional recommendations and governmental legislation, we’ll hopefully learn more about how to effectively extinguish fires and keep our environment and people safe.
How Vanguard Can Help With AFFF Disposal
At Vanguard Fire & Security Systems, our Industrial Fire Protection team can help with the safe disposal of AFFF. And as more fire protection manufacturers begin to develop alternatives for AFFF, we can help make system modifications to transition you to a different solution.
And, due to the growing importance of this topic, especially as Congress looks to vote on the PFAS Action Act, we’ll dedicate more time to creating and publishing information on firefighting foams, safe AFFF practices, reducing the use of AFFF, and potential alternatives.
If you’re looking to learn more about AFFF, how it affects the environment, and how to transition it out of your facility, contact us online today.