AFFF and PFAS At Forefront of Federal Action This Week

Not lengthy after the Division of Protection (DOD) offered a report by which it recognized substitutes for PFAS-containing AFFF however indicated that every may not be possible, legislators yesterday continued to use strain to the federal authorities with proposed laws to ban the manufacture, import, and sale of any PFAS-containing AFFF in the USA. Whereas the federal government (each federal and state degree) has proven a dedication to discovering methods to part out the use of PFAS-containing AFFF, the DOD’s evaluation of AFFF and PFAS free substitutes shouldn’t be ignored, particularly for proponents involved about potential regrettable substitutes for PFAS-containing AFFF.

The DOD’s AFFF and PFAS Report

In a recent report concerning the viability of AFFF-free substitutes for PFAS-containing AFFF, the DOD recognized six potential choices for phasing out the use of PFAS-containing AFFF; nevertheless, it recognized points with every potential resolution. The report was a benchmark by the DOD in its efforts to adjust to a Congressional deadline of October 1, 2024 to part out all PFAS-containing AFFF, which was half of the 2020 National Defense Authorization Act (NDAA). The NDAA additionally accommodates a requirement that by October 2023, the DOD difficulty a army specification (Mil-Spec) for firefighting foam that doesn’t include PFAS.

The DOD recognized six options for changing PFAS-containing AFFF – one PFAS-free foam and 5 engineering controls. The PFAS-free foam, Hello-Ex, is succesful of smothering fires when sprayed; nevertheless, the DOD notes that Hello-Ex could be very costly and “some structures [will be] unable to bear heavy foam generators” crucial to make use of the Hello-Ex product.  The DOD additionally famous issues that the Hello-Ex foam might not act as shortly as desired in smothering massive fires, which can permit fires time to develop in measurement, in addition to a priority that the froth producing system is “susceptible to accidental activation”, which might trigger property harm.

In distinction to foam merchandise, the DOD additionally particulars a number of engineering options, together with water-based sprinkler applied sciences and structural options – trench nozzles and ignitable liquid drainage flooring. The structural options, the DOD notes, include excessive value tags to retrofit all services with these engineering options. Additional, the DOD notes that water-based options, whereas environmentally fascinating, don’t conform to required code in that they can not adequately extinguish gas fires.

Upcoming AFFF Laws

Representatives from each the Home and Senate introduced yesterday that they may introduce companion laws in each chambers of Congress. The proposed laws would ban the manufacture, import, and sale of PFAS-containing AFFF.  The textual content of the invoice isn’t but accessible, however representatives famous that the invoice would require a whole ban at airports by October 2024. To assist the necessity for the invoice, representatives pointed to the truth that a number of different nations have enacted AFFF and PFAS bans already, and the present laws requiring the federal authorities to search out substitutes doesn’t go far sufficient. Statements made by proponents of the upcoming invoice confused that viable alternate options to PFAS-containing AFF exist; nevertheless, the DOD report is at odds with that assertion.

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