The information and policies concerning foam used to fight fires evolves so quickly that it’s hard to keep up with the changes, says Greg Jakubowski, a senior engineer for fire and safety with Buckeye Partners in Houston.

Jakubowski led a webinar Jan. 19 for the Society of Fire Protection Engineers. Titled “Firefighting Foam Considerations for Fire Departments,” the presentation focused on the hazards involved with using foam products and the steps departments can take to mitigate problems.

Water has a limited effect in extinguishing flammable liquid fires, making foam a preferred method for battling them. It smothers the liquid like a blanket to prevent oxygen from feeding the fire.

However, research shows the dangers these chemical compounds pose to people and the environment, poking holes in the idea that foam is the right tool for putting out these types of fires.

Departments must match foam concentrates to the type of burning fuel to which they are applied. Different foam concentrates cannot be mixed together, although finished foam products can be, says Jakubowski. It is still essential that whoever mixes the foam create it in the proper concentration and deliver it with the proper pressure.

Per- and polyfluoroalkyl substances (PFAS) are a large family of manmade chemical compounds found many consumer products, such as nonstick products, polishes, waxes, paints and cleaning products. Those chemicals also are the active ingredient in fluorinated foam products.

There are two types of firefighting foams:

  • Class A materials are used more as wetting agents than as foams. They break down surface tension of water so to better penetrate Class A combustible materials in forest fires and structural blazes.
  • Class B foams contain two PFAS compounds, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), which may be present in aqueous film-forming foam solutions (AFFF) solutions used in firefighting. They also can be present in turnout gear worn by first responders.

Compounds used to create AFFF solutions be found in either:

  • Foam concentrates stored in tanks, totes and drums.
  • Solutions where concentrates have been mixed with water.
  • Finished foam, where solutions are mixed with air and dispensed from discharge devices.

Hidden Dangers

Using AFFF products presents hidden dangers, according to the U.S. Fire Administration, which issued guidance pertaining to these hazards. For example, PFAS/PFOA/PFOS may be orally ingested, absorbed through skin or inhaled through exposure in the atmosphere. The compounds are not just found in foam concentrates, but also in Scotchgard waterproofing products and some work boots.

"Once exposed, PFAS can accumulate inside the body," says Jakubowski. "Long-term exposure in high concentrations can cause a buildup which can lead to increased risks of thyroid disease and testicular, kidney and bladder cancers."

He recalls an incident at a Wolverine manufacturing plant in Rockford, Michigan, where extremely high levels of PFAS chemicals polluted the groundwater. In fact, testing in November 2017 found PFAS concentrations at 532,000 parts per trillion (ppt) and PFOS/PFOA levels at 490,000 ppt. By comparison, the Environmental Protection Agency considers levels of 70 ppt large enough to trigger a health advisory.

Many fire departments have used AFFF foams in training for many years, which exposed firefighters to dangerous PFAS concentrations. Because of those risks, people now hesitate to use anything on larger Class B hazards that were not specifically tested for that purpose.

"Nobody seems willing to light their big tank on fire to see if a foam product works," Jakubowski notes. "It's also hard to get air permits for burn testing, and tests also require significant cleanup."

Stored Hazards

Most fire departments have a truck that carries 20 to 30 gallons of foam concentrate, which is mixed onsite at an incident and dispensed to smother burning liquid.

However, some storage facilities install foam systems to aid in suppressing fires or to reduce the chance of one starting. Flammable liquids themselves don't catch on fire, but the vapors they emit do, says Jakubowski.

The problem with foam storage systems is they eventually run out of concentrate and firefighters unknowingly start spraying water onto a foam blanket, which works to break it down, he explains. The system also can be over pressurized from the fire department connection, which could insert more water than desired to prevent good foam from forming.

Jakubowski urges fire departments to do extensive preplanning to identify the location of all foam storage areas within their jurisdictions and the type of foam present in those systems. For buildings protected by foam systems, fire departments need to know in advance how long the supply will last and what pressure is required for the equipment to operate at peak efficiency.

"I encourage departments to put those numbers in preplans and mark them on the building as well," he says.

Government Bans

Because PFAS/PFOS firefighting foam concentrate is persistent, bioaccumulative and toxic, government entities at all levels are acting to ban its use. As a result, new regulations are regularly being developed.

For example, Washington state banned AFFF concentrates in July 2020. Connecticut sought to eliminate PFAS foam by October 2021, but the pandemic and related staff shortages delayed this effort.

Seven states introduced take-back programs that removed foam concentrates from municipal storage and disposed of it properly.

Disposal is one concern, but replacing concentrates is another. Not only does buying a new product cause budget problems for most departments, but there’s also no clarity on what product to use instead. Some replacement foams don't meet the specifications required for certain applications.

Jakubowski credits Michigan for developing resources for local fire departments.

"A good indicator that a foam contains PFAS is if it mentions fluorosurfactant, fluoroprotein, C6 or any use of ‘fluoro’ likely means a fluorine component is involved," one document notes. "However, not all fluorinated surfactants are made of PFAS."

"The best thing to do is note the foam manufacturer and brand, then contact the company in writing to see if PFAS was used in its production and ask for the safety data sheet," Jakubowski explains.

Michigan also prohibits training with Class B AFFF foams and cautions departments not to spray the foam until they have an environmental OK. They can still use foams for hydrocarbon fires, on alcohol-based products and for aviation accidents, but only to save lives and protect critical infrastructure, Jakubowski explains.

Whenever departments use the foam, they must report its use to the Michigan Pollution Emergency Alerting System hotline, which is something other states are looking to implement as well.

"Incident commands will have to decide whether to let a fire burn or use foam to protect lives and important infrastructure, like high-traffic bridges," he adds.

Staying Safe

The most important thing fire departments can do is to protect people against exposure, and that means ensuring firefighters aren't foamed up with AFFF products.

Jakubowski says any departments using AFFF with PFAS/PFOA/PFOS should practice these controls to stay safe from exposure:

1. Replace older AFF stocks with fluorine-free foam solutions. However, those solutions are limited because foams are not listed to work in every situation. For example, some foams are listed only for tank firefighting, some with foam water sprinkler systems, and some only for municipal use with portable application equipment.

"Fluorine-free foams change weekly as more products are listed after more testing takes place," he says. "Some products have had their listings expanded."

2. Contain and manage AFFF and water runoff. Firefighters must treat any solution spill or runoff as a hazardous material incident, and that applies not only to liquid on fire, but to the agent as well, Jakubowski explains.

"Personally, I recommend you call your state's environmental people if you use the foam. Make a notification just as if it were any other type of spill," he adds.

3. Wear personal protective equipment (PPE) and use self-contained breathing apparatus (SCBA) when handling AFFF. Carefully remove and bag contaminated clothing and equipment prior to transporting.

4. Use cleaning wipes on face, neck and hands immediately after exposure. Then firefighters should shower within one hour of returning to the station or their homes.

5. Thoroughly clean all contaminated PPE and SCBA before its next use. Remember, the EPA measures hazardous exposure to PFAS/PFOA/PFOS material in terms of parts per trillion, not parts per million, Jakubowski explains.

Hazard Considerations

The first thing an incident commander must do is weigh the risk to people, property and the environment before deciding whether to use foam to put out a fire.

"Life safety is not a question. If you need to use foam to protect a life, you are certainly going to do that," Jakubowski stresses.

Commanders must evaluate what will be lost they allow the fire to burn out. The next question will be where to put the pollution, and those answers aren't always clear.

"What is your overarching strategy for fire protection?" he asks. "Is it a fire on a tank farm that will just burn while you cool surrounding tanks? Or is it a building fire that impinges on a chlorine storage facility?"

The need for preplanning is exceptionally high, so fire responders know what chemicals they are dealing with and the type of foam that will be most effective to use. That preplan also must include the location of buildings where foam is installed or stored.

Commanders also should evaluate mutual aid options.

“Foam is expensive to buy and costly to dispose, plus it needs to be tested every year to ensure it meets manufacturer specifications,” says Jakubowski. “Therefore, is it important for every department to maintain a supply of all chemicals, or can departments share the burden by stocking specific foams that can be shared with others? Or should they should store all the material at the county level and dispatch it where needed?”

Departments need to evaluate inventory levels to understand what they have available and in what amounts.

"The old stuff still works, but you need to understand what the hazards are to using it," he explains. "New products may perform the same as the old but will breakdown more quickly and have to be reapplied more frequently."

Always store the material somewhere where it is not likely to leak, but also develop secondary containment so that if the concentrate leaks, it won't go down the drain.

"There are more alternatives today than there have been in the past, and more products are coming out regularly," Jakubowski explains. "Do the research and check the listings.

"The bottom line is that if you're working in a foam environment, pay close attention to what's going on," he adds. "We are going to find out a lot more as we move forward."