The fire protection industry has concerns with the Queensland Department of Environment and Heritage Protection’s draft policy on firefighting foams, and calls for modifications.
Firefighting foam is a suppression agent used for controlling and extinguishing fires involving flammable liquids.
Recently there has been an increased focus on environmental effects from using firefighting foam, often without due consideration for other important issues such as firefighting performance, firefighter safety and system compatibility.
The Queensland Department of Environment and Heritage Protection (DEHP) has released a draft policy on the use of firefighting foams. While its intention to improve environmental outcomes is to be praised, the policy has several serious shortcomings that not only undermine the aim of reducing environmental effects but would also have adverse effects on safety for firefighters, personnel in hazardous industries and the community in general.
It’s hoped that by way of this article the concerns the fire protection industry has with the draft policy will be more widely appreciated and will lead to the draft policy being modified so that improvements to both environmental and fire safety outcomes can be achieved.
Points of agreement
FPA Australia agrees with several parts of the DEHP draft policy:
- All firefighting foams have adverse environmental impacts.
- Foam containing the surfactant PFOSshould be banned and existing stocks removed from service and destroyed.
- All foam and fire water effluent should be managed in an environmentally
- End users should transition from fluorinated foams containing perfluorooctanoate (PFOA) and carbon chain length C ≥ 8 (over a suitable transition period).
FPA Australia notes that existing fluorinated foams containing PFOA are being reformulated to eliminate PFOA and these will soon become available.
FPA Australia’s concerns
While some common ground exists, FPA Australia has serious concerns with parts of the DEHP approach. In particular, FPA Australia believes that promoting selection decisions based only on the environmental properties of firefighting foam concentrate is a flawed approach.
Firefighting performance is equally important in determining the environmental outcomes for an incident (e.g. duration, toxic combustion products and volume of fire water effluent produced), as well as business continuity and safety of firefighters, hazardous facilities and the community in general. Choosing the best firefighting foam for an application must, first and foremost, be based on selecting the best product to protect people, property and the environment. This requires selection based on a balance of firefighting performance, reliability and life safety, with minimal toxicological and environmental effects. As a general guide the Association recommends the following criteria be used for firefighting foam selection:
- firefighting performance
- life safety
- physical properties and suitability for use on known hazards
- compatibility with system design and approvals
- environmental considerations.
Although environmental performance is important, failure to adequately consider the firefighting and system performance aspects may result in selection of a foam that is ineffective for extinguishing fires.
This can lead to greater environmental impact resulting in longer extinguishment times, use of larger quantities of foam and water and the production of significantly greater quantities of firewater effluent, which requires disposal.
Firefighting foam is part of a system Evidence of suitability (certification) must be provided to demonstrate any foam’s ability to achieve the required firefighting performance for the fuel in question, following appropriate and recognised testing. Evidence of suitability must also be used to demonstrate that the foam
is compatible with associated systems and equipment. It is not always possible to change the type of foam used in a system without having to make significant modifications to the system. For example, many foams have high viscosity and may not be able to be correctly proportioned using existing hardware in systems where low-viscosity foams were previously used. Any proposal to change the type of foam used in a system requires careful consideration and must take fire safety and engineering factors into account.
The type of foam used should not be changed without completing a detailed review of the design, performance and operation of the system as a whole. Such design reviews should include consultation with fire system designers, foam and foam hardware suppliers and the relevant authority.
No such thing as environmentally friendly foam
Let’s be clear – there is no such thing as environmentally friendly foam. All firefighting foams have adverse effects on the environment. However, it must also be recognised that fires – especially those involving flammable liquids and other chemicals – also have significant adverse environmental effects in their own right. It is a general objective to extinguish a fire as quickly as possible.
In achieving this objective there is a positive effect in terms of minimising risk to life safety, property, the environment and business interruption. Specifically, using the minimum possible quantity of foam and water to control or extinguish the fire is greatly beneficial because it reduces the environmental impact by reducing the amount of fire water effluent to be managed post incident. Good firefighting performance is critical to good environmental outcomes. Therefore, firefighting performance cannot be ignored when making selection decisions aimed at minimising environmental impact. Poor firefighting performance is worse for the environment because of:
- longer extinguishment times – risk of escalation, more toxic combustion products, risk to life, property and business continuity
- use of larger quantities of foam and water – more toxic and contaminated effluent
- life safety concerns – e.g. slow knockdown, poor flashback resistance, unreliable post-fire securement and risk of escalation.
Not all foams are equal
Firefighting foams have different firefighting performance. Effective firefighting foams must:
- be compatible with the foam proportioning and delivery equipment
- cool the fuel surface
- protect from re-ignition
- resist attack or breakdown by the fuels (in particular, polar solvents)
- resist mixing with the fuel
- spread rapidly over the fuel surface
- Suppress the release of flammable vapours.
Significantly, firefighting foams containing fluorinated surfactants have valuable firefighting performance characteristics that historically have been unmatched
by F3. These performance advantages, which include improved firefighter safety and increased firefighting effectiveness (vapour suppression, knockdown and burnback), can significantly reduce the amount of foam required to control an incident and limit damage to the environment and risk to life and property.
That said, some F3 foams have recently achieved compliance with Australian Standards for use in portable fire extinguishers and pre-engineered systems, and development continues to improve F3 performance.
Less post-fire effluent
Better firefighting performance means less post-fire effluent. These performance differences are not limited to small-scale fire tests. An incident at Caltex’s Banksmeadow terminal in Sydney in July 2013 provides a real-world example of
the significant performance difference between F3 and fluorinated foams. Foam was used for vapour suppression and to prevent ignition of a large 175,000-litre fuel spill. When using fluorine-free foam (F3), effective vapour suppression (maintaining vapour levels below the fuel’s lower explosive limit) was only achieved for 15–20 minutes before foam needed to be re-applied. However, when fluoroprotein foam was later used, vapour suppression was achieved for 90 minutes.
This example demonstrates that use of fluorinated foam provided significantly longer protection and reduced frequency of re-application at that time. It also serves to demonstrate that using a foam with superior firefighting performance can significantly reduce the amount of foam and fire water effluent that needs to be managed post incident.
No silver bullet
Fluorine-free foams do not provide a ‘silver bullet’ solution to environmental problems associated with the use of firefighting foam. As demonstrated above, using F3 in some fire incidents could require significantly larger quantities – three or more times the amount – of both foam and water to manage an incident because the firefighting performance is inferior to fluorinated foams.
Poor firefighting performance equals increased risk. The draft policy incorrectly implies that the total risk resulting from an incident, up to the point the incident is controlled, will be the same regardless of the type of firefighting foam used. That is, the draft policy assumes that the firefighting performance of all foams at a given incident will be equal. As illustrated in Figure 2, this is not the case.
Hazardous facility managers need the flexibility to use risk management principles to select the most appropriate foam to manage the particular risks. The risk management for these facilities must be considered holistically, from pre to post incident, and not be based solely on the environmental properties of the concentrate.
Contamination and using F3
Using F3 doesn’t eliminate existing contamination. The Queensland DEHP draft policy incorrectly assumes that if
F3 has been used at an incident there will be no contamination with fluorinated compounds in the firewater effluent. Changing to F3 does not eliminate long-chain fluorinated compound contamination in facilities that have previously used fluorinated compounds. Long-chain fluorinated compounds can be present many years after changing
to F3. The experience at AirServices Australia sites demonstrates this situation.
AirServices Australia sites changed to F3 five years ago; however, soil and groundwater at these sites is still contaminated by PFOS. As a result, FPA Australia believes all firewater effluent should be considered to be contaminated and that it be contained and tested before determining the appropriate method of treatment and disposal, regardless of the type of foam used.
Proper management of firewater effluent is important to minimise adverse environmental effects. FPA Australia believes environmental policies should focus on stipulating how the firewater effluent from an incident should be managed irrespective of the type of firefighting foam used. The mantra for the management of all firewater effluent should be – contain, test, treat.
Risk must be managed holistically
The environmental risks resulting from fires in hazardous facilities must be managed holistically. Environmental regulators must acknowledge that different foam technologies have different firefighting performance characteristics and these can significantly affect the environmental outcome of an incident.
FPA Australia believes that foam users must be allowed to select the foam to best manage their risk and endorses the approach to selection and use adopted by the UK Environmental Protection Agency. It allows emergency services and hazardous facility managers to select and use the most appropriate foam concentrate to best manage their risk (putting out the fire as quickly and efficiently as possible – fewer combustion products, increased safety, less foam and water usage and less effluent to manage afterwards).
We recommend that Australian regulators adopt a similar approach. FPA Australia believes broad industry consultation is required to address the concerns of this draft policy. Regulators must engage in open, meaningful and transparent discussion to ensure any proposed policy and its effects are fully considered and are compatible with life safety objectives in the first instance. Regulators must not base post-fire effluent treatment decisions purely on the type of foam concentrate used. All firewater effluent must be treated as contaminated with long-chain fluoro chemicals regardless of the type of foam used (unless on-site testing proves otherwise).
The draft policy’s proposed restrictions on the use of C6 fluorotelomers are unnecessary. The restrictions would effectively prohibit their use despite these new-generation fluorinated foams, produced in accordance with the US
EPA Stewardship Program. C6 foams are a legitimate and environmentally acceptable option alongside fluorine-free foam and should therefore attract similar conditions for use to those prescribed for fluorine-free foams. There is no precedent either within Australia or in any other country for such onerous restrictions on the use of C6 fluorotelomers.
Finally, industry must be allowed sufficient time to transition from existing foam stocks of C8 (non-PFOS) to either US EPA-approved C6 formulations or F3 as appropriate to the particular facility or application.
For more information, go to www.fpaa.com.au