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). ADEQ supports and understands that the priority of firefighters and first responders is to protect life and property. 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.

Two major classes of Firefighting Foam exist, which include:

• Class A Foam: Used to extinguish Class A materials, such as wood, paper, brush and vegetation (wildland), is widely used by many fire departments for structural firefighting using compressed air foam systems.
• Class B Foam: Used to extinguish Class B materials, which include gasoline, oil, and jet fuel.

The discharge or use of class B firefighting foam that contains intentionally added PFAS chemicals for training or testing purposes is prohibited 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:

• A.R.S. 36-1696 | View Statute >
• S.B. 1526 Fact Sheet | View Document >

ADEQ strongly recommends fire departments and LEPC emergency responders review and consider the information provided here 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.
• Uncontrolled release of AFFF to the environment has the potential to create adverse impacts to public health and the environment if it reaches 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.

Regulation of PFAS has increased at federal and state levels. This increase has been accompanied by lawsuits brought on behalf of states, municipalities, and water districts for costs associated with removal of PFAS from drinking water sources. Specifically, AFFF that contains PFAS is the subject of thousands of ongoing legal actions.¹

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.

The Interstate Technology and Regulatory Council ITRC has compiled resources with additional information on AFFF and managing environmental risks posed by AFFF | Learn More >

U.S. Department of Defense (DOD) 

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.

The National Defense Authorization Act for Fiscal Year 2020 required, in part, that DOD discontinue use of AFFF at its installations after Oct. 1, 2024 – with waivers possible until Oct. 1, 2026, and an exemption for shipboard use. The military departments have developed implementation plans, schedules, and costs for replacing AFFF in all land-based mobile assets and facilities worldwide | US GAO Report >

In January 2023, DOD published an F3 military specification (MILSPEC), and foam manufacturers can now submit MILSPEC F3 agents for qualification by DOD. Once DOD certifies that a foam meets the new specification, it will be added to the Qualified Product List.

Federal Aviation Administration (FAA)

In December 2022, Congress directed the FAA to prepare a transition plan to ensure an orderly move to MILSPEC F3 for aircraft firefighting. The FAA has developed an Aircraft Firefighting Foam Transition Plan in coordination with DOD, the Environmental Protection Agency, and industry partners | View > 

PFAS-Free Solutions

If you are not sure if your firefighting foam contains PFAS, ADEQ recommends you contact the supplier or manufacturer directly. While the State of Arizona does not endorse or recommend any specific product, fire departments and emergency responders can view information about PFAS-free solutions from resources such as Interstate Chemicals Clearinghouse and GreenScreen for Safer Chemicals or consult the DOD Qualified Products List. Performance and testing of PFAS-free solutions is ongoing.

Additional Resources: 

• Interstate Chemicals Clearinghouse | Learn More >
• GreenScreen for Safer Chemicals | Learn More >

¹ AFFF Products Liability Litigation (MDK No. 2:18-mn-2873-RMG) | View >