Australian Foam Forum Raised Important Questions

Interesting updates from European and Australian regulatory organisations, five presentations from Fluorine Free Foam (F3) supporters and two from fluorine containing foam supporters, stimulated thought provoking questions. The discussion was unusual because it declared a key objective at the start “To produce a position paper for foam procurement”, which soon became a vital part of the proceedings.

Several delegates were sceptical, as the conference had been organised and sponsored by a single F3 manufacturer, which led to the first important question: Should we only value discussions where all sides of a difficult issue are encouraged to work together, to provide realistic outcomes and workable solutions?

Positive Position Paper

It became clear that this position paper was starting a process to develop and implement a sound, secure and prudent procurement policy, in a co-operative atmosphere of sharing and learning. Undertaken by a Government organisation and delivered by a powerful partnership of science, industry and Government called CRC – Care, which was set up to devise new ways of preventing and ameliorating soil, water and air contamination. Technical input seemingly comes from a single F3 producer and sponsor of conferences, which is concerning and hardly seems right. Would not this policy, like any other, benefit from diverse inputs of a broad range of stakeholders – strengthening, informing and benefitting the outcome?

I was privileged to be part of the UK Department of the Environment’s world leading Risk Reduction Strategy for PFOS, as a stakeholder representative, where this inclusive approach worked well. Why could not such a diverse stakeholder engagement format be followed here? At least a draft policy document should be passed around this delegate group. It represents a “ready-made” well informed, diverse and interested “sub-set” of stakeholders, on which to build. Only time will tell whether this happens, but at least a list of attendees plus contact details was circulated – an important first step.

A risk and impact assessment approach was favoured for adoption to cover Class A and Class B foams, with possible essential uses in certain areas. Acceptance of different foam suitability for different hazards, plus improving containment profiles, would help justify some foam types over others. A desire to establish what is fit for purpose, a review of containment, mitigation measures and disposal options, was also agreed. A number of gaps in our knowledge were highlighted, that would need answers to better inform the resulting position.

While we only expected to set some broad policy headings in such a short forum, it was important to define and clarify key parameters, and identify key gaps in current knowledge. Both are pre-requisites for any meaningful policy. Now we had the potential for a genuine attempt to place clear, fair and possibly unbiased guidelines of significant potential benefit around the world, not just in Australia.

A very balanced and frank approach came from NICNAS (Australian National Industrial Chemicals Notification and Assessment Scheme), which is working hard to scrutinise new chemicals and develop a framework of controls for Persistent, Bioaccumulative and Toxic (PBT) fluorochemicals like PFOS. It seems NICNAS accepts the need to separate these undesirable PBT chemicals deserving tight controls, from PFOS-free foam concentrates, increasingly using C6 telomer-based fluorosurfactants that deliver fast fire control with firefighter safety benefits.

Regulatory Environment Update

Germany took the most precautionary approach having set threshold levels for perfluorinated carbon compounds (PFCs) in drinking water and sewage sludge in 2010. Underway are a range of studies into PFC build up in soil, groundwater and vegetables. After bans on usage and storage of PFOS based chemicals in Europe (June 2011), with disposal by high temperature incineration, concerns continue over persistence and transportation into remote areas. Strict international regulation on the use of PFOS under the 2009 Stockholm Convention has still not been implemented by most signatories outside the EU.

The US Environmental Protection Agency developed its PFOA stewardship program, which although voluntary, has been adopted by several major fluorochemical producers including Du Pont, who are ahead of schedule, exceeding 95 percent reductions by 2010. The company expects to achieve complete phase out of PFOA ahead of the 2015 target date. Canada legislated management of PFOA in 2010, ahead of its intended future phase out.

Norway and Germany are proposing restrictions on PFOA, particularly in consumer products, effective from 2016. Surprisingly there seems no concerted action from United Nations, which could minimise the use of PBT substances quickly, and reduce environmental build up.

Concerns were expressed that currently in Australia no written policy exists on the use of Class B fire fighting foams. Western Australia’s (WA) Department of Environment and Conservation is taking up this challenge with a more holistic and balanced approach, recognising that no environmentally benign foam exists, as all foams have some impact on the environment. Should we also be considering other important aspects including fire performance, efficiency, fire-fighter safety, incident escalation, aerial pollution, business interruption and loss of employment? Only then can the best and truest decision be made. Equally important are potential pollution incidents from oil emulsification, foam containment and disposal methods, plus soil and water remediation. There are large variations in fire performance and environmental impacts between different foam concentrates, for example, inherent benefits of modern detergent-free natural protein AR-FFFP products, which do not emulsify hydrocarbons and deliver low aquatic toxicity.

Aviation Implications

Research has shown that AFFF foams containing telomer-based fluorocarbon surfactants require up to three times less concentrate used on a given fire scenario, than alternative F3 products. This requires significantly less concentrate and water resources, plus less fire water run-off for collection and treatment. In a time critical application, could not this extra control time potentially cost lives?

NRL Testing

Recent US Naval Research Laboratory testing has shown fluorotelomer surfactant containing Mil F AFFF agents on a 2.6 square metre pool fire extinguished all four different hydrocarbon fuels tested within the 30 second performance criteria. This was between 70 percent and 88 percent faster than F3 foams. Research has shown this is largely due to the aqueous film forming ability of the fluorotelomer surfactant chemicals, when used through non-aspirating nozzles. These film-forming products maximise travel distances, keeping firefighters a safe distance from the fire, minimising wind effects. This maximises fire-fighter safety, achieves exceptional fire extinguishing performance, and provides the opportunity to quickly save lives. Can this be said of F3 alternatives, which should be applied aspirated, do not meet the Mil F criteria even at full strength, and have a tendency to sudden flashbacks, particularly when burning or incandescent materials are present?

Airservices Experiences

Airservices Australia operates air traffic and other essential airport services including Aircraft Rescue and Fire Fighting (ARFF), in all 39 airports around Australia. They are implementing a change-over from AFFF 6% to 6% F3 across the nation. Detailed and time consuming, this change-out process ensures no residual contamination in equipment, trucks, or even PPE gear.
It was surprising to hear that they do not see their priority as extinguishing aircraft fires, preferring it seems to control them and evacuate personnel. Supposing flashback or re-ignition occurs during evacuation? Does this conflict with perceptions that rapid extinction delivers maximum opportunity to save casualties and protect firefighters from danger? Reducing Australia’s fire test criteria to ICAO Level B from above Mil F standard, and many would say reducing its fire fighting capability from AFFF to F3 seems strange, when aircraft are more complex, more frequent, often with more passengers and more fuel – so does this make real sense? One would expect a tightening of requirements, perhaps a focus on extinction before trying to evacuate casualties, to reduce inherent risks of sudden flashbacks threatening passengers and firefighters alike – not the reverse?

Rigorous Testing

Mil F approved AFFFs have to extinguish the same 2.6 square metre fire tray at half strength within 45 seconds, recognising that only one fire truck may be able to reach the incident quickly, that a nozzle may become partly blocked, or some unexpected error occurs, restricting foam application to the fire. A safety factor is built-in so the foam still safely gets the job done, under less than ideal circumstances. This seems to be missing with F3 foams. NRL testing suggests there is no safety factor with F3 foams, and seemingly often no extinguishment within 45 seconds, even at full strength. So why are we accepting F3 so readily?

Individual risk assessments would match different solutions for specific applications. Should we restrict ourselves from the best answers, because we fear what may happen in future? Should we only consider new alternative approaches after rigorous life-size testing? Should we grasp the first potential answer, when it fails to deliver the robust solution we seek?

Way Forward with Telomer-based Fluorosurfactant Foams

A strong realistic approach was adopted, recognising that all foams have an environmental impact, so substituting one variety for another, does not solve our problems. How do we maximise the benefits from using any foam as sparingly as possible? Reduced loss of life, fast and efficient extinction, reduced atmospheric pollution and toxic gas releases, minimised incident escalation, and firefighter safety are all benefits derived from firefighting foams, but probably maximised by using telomer-based fluorosurfactant products.

Risk Reductions

A four-level hierarchy of risk reduction was discussed and used in the later forum session, from elimination by design; minimisation by design; use of appropriate engineered safeguards; and administrative controls (for example, safe work practices). It needs improved containment like bunding of foam and fuel storage tanks; better waste water collection with oil interceptors, spill containment kits, disposal through waste water treatment, plus improved operational procedures and work practices to make a difference.

Should we be considering these alternative, possibly better, approaches to minimising our environmental impacts, at least until better second generation F3 foams are developed that address some of the problems associated with current offerings? Minimised aquatic toxicity, less foam concentrate used, yet highest levels of fire performance are being delivered by modern C6 fluorotelomer surfactant-based products. Subjecting them to improved collection, disposal and treatment could be the way forward.

Fire-Water Treatment

Exciting research has been conducted by Du Pont to purify fire-water run-off collected after a fuel separator. This showed surprisingly effective results for both fluorinated and F3 foams. This pilot system used a four-part separation: electrocoagulation; flocculent segregation; reverse osmosis treatment and final activated carbon polishing. It reduces initial fluorosurfactant concentrations of 115ppm (parts per million) in the run-off down to 31ppm after flocculent segregation, down to 10-16 ppb (parts per billion) after reverse osmosis and activated carbon polishing, in two hours. It was equally effective at removing harmful hydrocarbon surfactants from F3 foaming agents, reducing their aquatic toxicity. This approach could be a credible solution to all these problems?
Initial equipment cost is currently high, but the operating costs of effluent treatment are reassuringly reasonable at around 1US$/m3, pointing a way forward to possibly having the best of both worlds: barely detected perfluorinated compounds in treated water released back to the environment, while retaining the most effective and efficient C6 fluorotelomer surfactant based firefighting foams to maximise fire performance and minimise environmental impacts. Perhaps this is the answer of the future, for all foam type applications?

Conclusion

Despite lacking answers to many of these important questions, both the organiser Dr. Klein, and Dr. Healy chairing the main discussion, are to be congratulated on the positive atmosphere produced and its contribution to this important debate. Developing a meaningful policy document, with as much diverse stakeholder input and rigorous questioning as possible, is a worthy outcome.

This conference scored highly by raising more questions than answers in a stimulating, co-operative environment, and has contributed to this long running debate. Let us hope we see good resulting actions.

For further information, go to www.cleanupconference.com



Mike Willson is a firefighting foam specialist

Pic courtesy of Frederic Gil