If fluorinated foams such as AFFF and
FFFP can cause environmental damage, is it possible to use fluorosurfactant
free foams in extinguishers?
This would be the ideal solution to the problem - but it is not
possible.
An extinguisher contains a relatively small amount of liquid and
requires the intervention of a physical barrier to shut off the
oxygen to the fire. This barrier is achieved by forming a film
on the surface of the liquid fuel (Class B). The fluorosurfactant
provides this film or barrier.
The minimum ratings required in the European Standard EN3 cannot
be achieved without this film formation.
During servicing of extinguishers
we have always discharged the foam at the clients premises. Why
do we need to change now?
Foam such as AFFF used in extinguishers is a List 1 material
described under the Ground Water Regulations 1998. You are not
permitted to discharge foam anywhere if it can eventually find
it's way back to ground water, either indirectly via surface water
drains or directly to land, such as hard standing, car parks,
grassed areas, soil or rough ground. The foam must be contained
at site or at the servicing company's facilities for proper disposal.
During servicing of extinguishers
we never discharge to land. Instead we discharge the foam either
to the client’s sewer or to our own sewer at our facility.
Why should we change now?
Foam discharged from extinguishers is a “trade waste”.
You are not allowed to discharge a trade waste directly to sewer
without the written consent and prior agreement of the water company
responsible for your area. Regardless of any previous practice,
the fluorinated material in foams such as AFFF, AFFF-AR, FFFP,
FFFP-AR cannot be identified by the water company and is therefore
not treated by them. The fluorinated material will remain in the
sludge at the water treatment plant which is then sent to agricultural
land. The water company unwittingly becomes the polluter as the
fluorinated material in the sludge has an indirect route back
to ground water.
Why has fluorosurfactant foam
become a major problem for the industry. This has never been an
issue before, why is it an issue now?
Over the last five years, studies have proved that fluorinated
materials generally have a detrimental impact, not just on the
environment but also on biological systems. Fluorinated material
is now found in human blood; this was not the case until the late
50's. The main cause of this phenomenon is more to do with packaging,
tapes, coatings etc. However, the environmental impact of fluorinated
foams is one of the reasons why 3M announced that it was to halt
manufacture of PFOS-containing fire fighting foam in May 2000.
I have been in the fire extinguishing
business for 30 years. This has never been an issue before, why
is it an issue now?
Doing something for 30 years does not make it right. We all have
a responsibility to ensure we do what is necessary to maintain
a healthy and sustainable environment. Dealing with waste products
from our industry in a proper and safe manner is one of our contributions
toward fulfilling that responsibility. Operating a business within
current legislation should be sufficient motivation for any Company
Director.
Surely it is the responsibility
of the foam manufacturer to take the foam back when it is discharged.
It is the foam manufacturers responsibility to supply a product
that is fit for purpose. It is supplied for the purpose of extinguishing
fire for the application you require.
It is not the manufacturers responsibility to deal with your waste.
The manufacturer supplies you with a concentrate material, not
a foam solution ( foam concentrate mixed with water).
What are foam manufacturers doing
to resolve the environmental issues of foam?
Most foam manufacturers have developed and to continue to research
new foam products and how best to deal with the very serious environmental
issues associated with foams. Some manufacturers have been able
to reduce the level of fluorosurfactants in their formulations
whilst maintaining acceptable levels of performance. However,
one thing is absolutely clear. If the foam you are using contains
fluorosurfactants of any kind, the degradation products from these
foams will persist in the environment for decades and thus need
to be contained and treated accordingly.
Foams containing, or which have
a degradation product known as PFOS are no longer manufactured.
So why should we be concerned about PFOS any longer?
It is true to say that most recent fears about foams have been
related to PFOS. There are two distinct problems that must be
considered. First of all, although PFOS foams are no longer manufactured
many thousands of tonnes of super-concentrate are still available
in the market place. They will remain in the industry for at least
the next 10 years or more. PFOS is classed as very persistent
(vP) in the environment, it is bioaccumulative and toxic. All
of this research information is documented. Secondly, as a service
engineering company you may not know what foam is contained in
any particular unit of equipment and should treat all foams on
a worst case basis.
My foam supplier confirms that
the foam he supplies is not PFOS based but produced via the telomer
process. Is it OK for me to put this foam down the drain?
In short, No.
Foams manufactured today use fluorosurfactants manufactured using
a Telomer process. The degradation product from these foams is
known as H-PFOS. There is currently not sufficient data to show
whether these foam degradation products are as toxic or bioaccumulative
as PFOS. However, they are known to be extremely persistent in
the environment and remain as List 1 materials under the Ground
Water Regulations 1998 and so must not be discharged to ground
water. In terms of dealing with waste, all fluorinated foams should
be dealt with by containment and treated to remove the fluorosurfactants.
What is the difference between
the PFOS and H-PFOS molecule?
Complicated molecules of a similar chain length can act in a
similar way. Both PFOS and H-PFOS have the same chain length and
a very similar structure. They both contain eight carbon atoms.
In the PFOS molecule all eight carbon atoms are fluorinated. This
molecule is very persistent (vP), bioaccumulative (B) and Toxic
(T) and therefore classified as PBT. In the H-PFOS molecule, commonly
described as 6:2 FtS or fluorotelomer sulphonate, six of the eight
carbon atoms are fluorinated. This molecule is known to be extremely
persistent (vP) in ground water. Research in the USA by the Environmental
Protection Agency and other Environment Agencies elsewhere in
Europe continue to try to ascertain the environmental impact of
Telomer foams with regard to bioaccumulation and toxicity.
When and where can fluorosurfactant-free
foams be used?
Fluorosurfactant-Free Foams (FSFF) can be used successfully in
the vast majority of applications by the Fire and Rescue Service
or Fire Bigades. More than 95% of all fires attended by Fire and
Rescue Services fall into one of the following categories:
house fires; car fires; industrial fires such as a pallet fires;
tyre fires; fires containing plastics, paper, any solid fuel materials;
fuel spillages, either hydrocarbon or polar solvent (alcohol).
Products such as ECOPOL (FSFF-AR) or BIO FOR N (FSFF) are foams
that are fluorosurfactant-free and can deal successfully with
all the above.
Can FSFF and FSFF-AR replace
AFFF and FFFP used by the Fire and Rescue Service?
There is no logical reason for the Fire and Rescue Service to
use AFFF or FFFP for most foam application operations.
FSFF should be used in all applications unless a specific risk
and area involving a high volume hydrocarbon fire has been identified
by the Fire Service. In cases of large fuel tank fires, a foam
which produces film formation and a protein blanket is more appropriate
for that risk. Foam developers continues to look for alternatives
to film formation in foams.
What if a Fire Service is called
to assist another Service at a large tank fire and they carry
FSFF but not AFFF or similar foams?
The Buncefield fire is a typical example. It is important to
note that in the vast majority of fire incidents where the Fire
Service attends a high risk site, the site operator will generally
store or supply the fluorosurfactant foam required. This was the
case at Buncefield, where the Fire Services attending provided
Command and Control, fire fighting skills, logistics and techniques,
and the hardware such as vehicles and water pumping facilities
to deliver the foam. The site owners bought and supplied the foam.
How does the Fire Service contain
the foam at the site of a car fire or any other typical fire they
deal with on a day to day basis?
It is unlikely that any Fire Service can contain foam used at
an incident unless of course it is a tank fire which is bunded.
This is why it is essential that the Fire Service use a foam product
that is fluorosurfactant-free. This will ensure that fluorinated
material does not reach water systems such as ground water and
rivers.
Which Fire Services in the
UK use fluorosurfactant-free foams?
Mid and West Wales Fire and Rescue Service developed their strategy
for using FSFF in 2002 and lead the UK Fire Service in this regard.
All new build foam carrying vehicles use ECOPOL and BIO FOR N
in conjunction with the Hydroflow 500A/B foam system.
This system delivers the foams at induction rates of between 0.1
and 3%. Needless to say, they use lower volumes of foam than previously
experienced and their foam application is environmentally responsible.
The foams also meet all their training requirements safely and
in the knowledge that there is no environmental impact. Since
2003, British Nuclear Fuels Limited (BNFL) have been using ECOPOL
(FSFF-AR) and BIO FOR N (FSFF) at their Salwick site near Preston,
UK.