ADEQ is providing fire departments, local emergency planning committees (LEPCs) and EPCRA Tier II industries in Arizona with this online information resource to better understand potential health and environmental risks and consequences associated with continued use of aqueous film forming foams (AFFF) containing PFAS (per- and polyfluoroalkyl substances). This resource provides important information to support decision-making about firefighting using AFFF and its alternatives so that potential impacts to the environment can be minimized and mitigated.
ADEQ understands the priority of firefighters and first responders is to protect life and property. Understanding and mitigating the potential risks associated with environmental releases of AFFF containing PFAS is prudent. The discharge or use of class B firefighting foam that contains intentionally added PFAS chemicals for training or testing purposes unless required by law or done in a facility with proper containment, treatment, and disposal measures is prohibited by Arizona state law. See details below:
ADEQ strongly recommends fire departments and LEPC emergency responders review and consider all information and resource links provided in order to implement best practices to reduce the risk of AFFF releases to the environment. Protecting Arizonans and Arizona’s water resources from PFAS impacts is critical.
PFAS, a group of chemicals called emerging contaminants, are linked to adverse human health outcomes from exposure.
Some studies have shown that certain PFAS may increase the risk of cancer, affect the immune system and impact children’s development and additional research is ongoing | PFAS Resources >
The most significant PFAS human exposure pathway is drinking impacted municipal or well water.
PFAS are persistent and certain AFFF firefighting foams can be a major source of PFAS release to the local environment.
Uncontrolled release of AFFF to the environment has the potential to create adverse impacts to public health and the environment if it reaches drinking water, groundwater or surface water.
ADEQ urges Arizona’s fire departments and emergency responders to take extreme care to minimize release of AFFF containing PFAS into the environment.
At this time, EPA has a drinking water Health Advisory Level (HAL) in place for two PFAS compounds and is in the process of making a regulatory determination related to establishing enforceable drinking water standards for certain PFAS. Regulation of PFAS is increasing at federal and state levels and is focused on lowering the limits for acceptable levels of PFAS in groundwater and soil, as well as requiring remediation projects to address PFAS contamination.
Increasing PFAS regulation is accompanied by hundreds of class actions, personal injury claims and individual lawsuits that have been brought on behalf of municipalities and water districts for costs associated with removal of PFAS from potable water sources. Specifically, AFFF that contains PFAS is the subject of more than 500 ongoing legal actions.1
What is the U.S. Department of Defense (DOD) doing related to AFFF and PFAS?
To prevent future releases to the environment, DOD stopped land-based use of AFFF in training, testing and maintenance through a department-wide policy issued in January 2016. When DOD must use AFFF in emergencies to save lives, releases are treated as a spill -- affected soil is contained and removed, ensuring no further PFAS is added to the groundwater.
DOD military departments are using data from investigating known and suspected releases of firefighting foam to identify affected public water systems and private wells and are providing alternative or treated water to address drinking water affected from DOD activities.
Looking ahead, DOD is investing heavily in researching fluorine-free alternatives | US DOD AFFF & PFAS >
Potential Sources of AFFF/PFAS Releases to the Environment
AFFF containing PFAS has been and continues to be stored and used for fire suppression, fire training, and flammable vapor suppression at military installations and civilian facilities and airports as well as at petroleum refineries and bulk storage facilities, and chemical manufacturing plants and storage. Additionally, local fire departments in communities may have used and may be maintaining AFFF in their inventories. Landfills that receive firefighting waste are also a potential source of release of PFAS to the environment.
PFAS are not required to be reported on any material safety data sheets (MSDS), as they currently are not considered a hazardous substance. To verify whether PFAS are ingredients in the foam you are using or have in your inventory, ADEQ recommends you contact the supplier or manufacturer directly.
EPA encourages the use of training foams that are available which simulate AFFF without containing PFAS | EPA & AFFF Webpage >