AFFF FIREFIGHTING FOAM SYSTEM REPLACEMENT
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Starting in July 2020, firefighting foam containing PFAS (per- and polyfluoroalkyl substances) was banned for sale within the State of Washington (Senate Bill 6413).* This is the first state ban that impacts all firefighting foam systems that utilize a fluorine-based foam, including AFFF (Aqueous Film Forming Foam). AFFF is commonly used in facilities to suppress high-hazard flammable liquid fires like jet fuels and gasoline. The presence of PFAS requires these systems to be replaced.
A discharge incident could result in significant business disruption and a potential release of PFAS contaminant to the environment. The discharge incident could be inadvertent (more likely), or due to fire. Also, and more importantly, if your facility is following NFPA and/or insurance requirements for annual testing, this can use up foam concentrate, leaving the system impaired without a discharge incident. The system could be impaired for a significant amount of time without the ability to purchase replacement foam.
Assessing your system in advance can prevent future unexpected shutdowns or delays. Each facilities’ equipment, hazards, and business operations are unique. If you utilize foam containing PFAS, Coffman recommends performing a foam system replacement study to review the current foam system design and hazards protected. This study will help to inform decisions on cost-effective system replacement options that can protect your facility and reduce business disruption.
Determine if your foam system should be replaced with our ‘Commonly Asked Questions’ guide. Download the guide by filling out the form to the right.
* Exemptions currently exist for airport responding fire departments, chemical plants, oil refineries, and federal facilities. However, these exemptions are being removed in a phased ban starting in 2023.
AFFF Replacement Results in Cost Savings for Puget Sound Energy (PSE)
Coffman was engaged by Puget Sound Energy (PSE) to review replacement options for an existing AFFF foam-water sprinkler system at their South King Center facility. Coffman was able to determine that the hazards protected by the existing system could be protected with a water-based fire suppression system utilizing an alternate means and method, which was accepted by the local Fire Marshal.
Replacing an existing foam-water sprinkler system with water-based fire protection is not a solution for all hazards, however, this solution saves PSE on the cost associated with the system replacement and future costs associated with system maintenance. The replacement project is currently on-going.
Timeline of planned bans and legislation
2020: January – New Hampshire restricts the sale of PFAS containing foam with exemptions (Senate Bill 257). July – State of Washington bans sale of firefighting foam containing PFAS (Senate Bill 6413).
2021: August – Colorado bans sale of PFAS-containing foam with exceptions (House Bill 19-1279). New York plans to ban the sale of PFAS-containing foam by the end of 2021 except terminals, oil refineries, chemical plants, and others as required by federal law (Senate Bill S439A).
2023: Washington State phased ban of PFAS products begins for federal facilities.
2024: Washington State phased ban of PFAS begins for chemical plants and oil refineries.
- EPA published federal action plan for PFAS and is implementing that plan.
- Washington State Department of Ecology – Toxics in firefighting law
- The Spokesman-Review – Washington bans firefighting chemicals that may cause cancer
- Chemical Watch – Expert Focus: US States outpace EPA on PFAS Firefighting Foam Laws