One of the primary problems with PFAS is their “persistence.” Persistence means they can persist in soil, water, and in the human body … for years. Exposure to water, air, and sunlight does little to degrade them, thus they are known as “forever” chemicals.
New Legislation on PFAS May Affect Your Fire Suppression System
Hasn’t this happened before?
Over the past few decades, the fire protection industry has been affected by national/international restrictions and bans on production of the chemicals used in fire suppression systems. The first and most notable event was the Montreal Protocol in 1992 that essentially halted the production of Halon®, categorized as a class 1 ozone depleting substance and the most popular clean agent of its time.
Halon was targeted because of its high ozone-depleting potential (ODP). The search for a Halon replacement led many manufacturers to hydrofluorocarbons (HFCs). In terms of fire suppression, HFCs provided a viable replacement to Halon without the ODP. However, HFCs were soon to be regulated by the Kyoto Protocol of 1997 on greenhouse gas emissions.
With the ongoing concern over climate change substances and materials with high global warming potential (GWP) have increasingly come under scrutiny from the U.S. Congress and other international governing bodies. Consequently, on December 27, 2020, Congress passed the American Innovation and Manufacturing (AIM) Act.
The AIM Act quickly curtails the production and consumption of HFCs, provides strict oversight on any remaining use of HFCs, and encourages innovation for HFC-free technologies. In terms of fire suppression agents, HFC 125 (trade name: FE-25®), and HFC 227ea (trade name: FM-200®) are both directly and adversely affected in terms of production, usage, and handling.
What are PFAS chemicals and how are they used?
The mission of the EPA is to protect human health and the environment. In its endeavor to fulfill that mission, the EPA has compiled a list of “contaminants of emerging concern”—substances that have recently been shown to be present in our environment and have the potential to harm the environment and/or public health. On this list are per- and polyfluoroalkyl substances (referred to as “PFAS” collectively) which are a family of chemicals that have several uses in the firefighting and fire protection world, among many other applications.
PFAS are a large group of industrial compounds, the most widely used and studied of which are perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS).
PFAS were developed in the 1930s, and it rapidly became apparent that they had several uses in industrial and consumer settings. In 1945, DuPont used PFOA to make Teflon®, a non-stick application for cookware. In the 1950s, 3M used PFOS to manufacture Scotchgard™, a waterproofing and stain-resistant application for fabric. In 1960, 3M used another PFAS to develop an aqueous film-forming foam (AFFF) for the U.S. Navy to combat shipboard fires.
At present, PFOA is no longer used in Teflon, PFOS has been removed from Scotchgard, and neither are used to make AFFF. However, new PFAS variants are still used in all three products as well as many other applications including:
Clean agent fire suppression
Water repellant in the moisture barrier of firefighter turnout gear
Liquid coolant in semiconductor processes
Friction reduction in the automotive, aerospace, electronics, and construction industries
Non-stick applications for food packaging
In short, PFAS are everywhere, and we are typically exposed to them daily. With these substances being so pervasive in our daily lives, it begs the question. . .
Are PFAS chemicals bad for you, and if so, how bad?
The short answer is “yes,” but we are just learning how bad PFASs can be. As an emerging contaminant of concern, we are still discovering how harmful PFAS are to people, animals, and the environment.
One of the primary problems with PFAS is their “persistence.” Persistence means they can persist in soil, water, and in the human body … for years. Exposure to water, air, and sunlight does little to degrade them, thus they are known as “forever” chemicals. Other notorious and persistent chemicals include polychlorinated biphenyls (PCBs) and dioxins, both of which were proven to be highly toxic and ultimately banned by the EPA in 1979.
Testing has shown that PFAS have contaminated soil, water, air, fish, and people in locations across the nation and around the globe. PFAS chemicals enter people and the environment through many vectors:
Drinking water contamination
Consumer products (e.g., cosmetics, shampoo, etc.)
Fire suppression agents (i.e., foam and some clean agents)
Contaminated fish and dairy products
Household products, clothing, and even dust in the home
With PFAS almost everywhere, one should ask, “What harm do PFAS chemicals cause?” Because they are considered an emerging contaminant of concern, we do not fully understand the extent of their risks. But the problem has been on the horizon for decades.
In 1999 a farmer in West Virginia sued one of the large chemical manufacturers over the death of his cattle downstream from the chemical plant. This story was documented in the book Exposure by Robert Bilott (2019) and made into the 2019 movie, Dark Waters.
A 2007 study by the National Institutes of Health found that PFOA and PFOS are present in the blood serum of approximately 98% of the U.S. public.
In 2019, the Environmental Working Group (EWG) tested 44 water sources in 31 states and the District of Columbia for PFAS. Forty-three (43) of the 44 locations had at least some PFAS, and 42 of the 44 had PFAS above EPA limits. In 34 locations with PFAS, neither the EPA nor state agencies had previously tested the water for PFAS.
Also, in 2021 an extensive medical study conducted in West Virginia revealed that there is a probable link between PFOA exposure and six potentially fatal medical conditions:
In addition to these outcomes, PFAS are also believed to decrease vaccine response in children, adversely affect liver enzymes, cause decreased birth weight, decrease the immune response, and may be linked to birth defects.
What is Congress doing about PFAS?
Currently, major chemical companies are working to avoid future problems with the EPA. Outcomes such as the $670 million settlement and $16 million+ EPA fine incurred by DuPont and Chemours (a new company spun off by DuPont in July 2015) as a result of the aforementioned West Virginia lawsuit have set precedents and are of serious concern to the chemical manufacturing industry. However, too often, alternatives and replacements for the primary chemical offenders come from similar chemical families, with questionable rigor in safety testing.
There are nearly 4,700 PFAS chemical compounds in existence. The EPA currently has the resources to measure and control only twenty-nine (29) of these substances. By utilizing an alternate chemical from the PFAS family, the possibility that these cousin-compounds may be harmful as well cannot be denied.
One alternate called GenX is already proving to be persistent and is showing up in water, soil, and air sampling studies. Toxicology studies conducted by the EPA reveal that GenX is more toxic than originally thought, even at low levels. It is particularly toxic to the liver and is capable of entering the bloodstream of unborn offspring.
Now, the U.S. Congress have intervened with several pieces of legislation aimed at curbing the ongoing PFAS issue. Currently, there are no less than fifty different pieces of legislation pending in the two houses of Congress. The PFAS legislation can be loosely grouped into the four following areas:
Enhanced detection and research
Military use of PFAS
These pieces of legislation are focused on informing the public of the dangers and risks posed by PFAS. They also address testing and monitoring for PFAS and educating physicians as to the proper treatment of PFAS-related illness and disease. Drinking water safety is a major element across all four of the focal areas since it is the route of exposure affecting the greatest number of citizens.
Concern for firefighter safety is also evident with four separate bills targeting PFAS use in firefighting foam and protective equipment. Over a quarter of the bills apply to the armed forces. This is based on research proving that the military is particularly hard hit, having 121 PFAS-contaminated sites and over 500 drinking-water sources that exceed the EPA’s limits on PFAS.
In addition to federal legislation, many states are also taking action against PFAS exposure. Since 2018, there have been hundreds of pieces of PFAS-legislation, resulting in thirty-one states banning the use of AFFF manufactured with PFAS. In addition to AFFF, at least two states have passed laws banning PFAS in cosmetics, and fifteen states have enacted laws pertaining to PFAS in drinking water.
The concern over PFAS is not limited to the U.S. The EU has banned over 200 PFAS substances, including AFFF, with the rule taking effect in 2023. Several states in Australia have also banned PFAS in AFFF, with similar laws expected to encompass the entire Australian continent in the near future. In 2019, the UN agreed to a global ban on PFOA giving member nations five years to comply.
How can this new legislation affect my fire suppression system?
If your fire suppression system contains AFFF manufactured with PFAS chemicals, then you will be impacted. The degree of impact will vary according to the state where your AFFF is used. Several states have already enacted laws that prohibit the sale, manufacture, and use of AFFF. And others limit the use of AFFF to actual firefighting and forbid its use in testing and training.
Reporting the use of AFFF is a newer requirement in many states, and a few states have instituted a buyback program to rid themselves of AFFF stocks. Regardless of where you operate, AFFF has met the same fate as Halon. It will go into history as yet another fire suppression agent that, despite its effectiveness, had too many dangers and risks to the planet’s occupants.
But AFFF is not the only fire suppression agent at risk of being banned. Any product containing PFAS variants could, by virtue of its inclusion in the PFAS family, eventually be subject to similar restrictions as other PFAS chemicals. Recall that there are over 4,000 PFAS chemicals, and the EPA has started to measure and control only a mere twenty-nine (29) of them.
With the funding being allocated for PFAS research, it is certainly possible that one day soon, other PFAS-containing fire suppression products could be determined to be a persistent chemical with hazardous characteristics. A business owner with tanks of PFAS-containing products in their fixed system could conclude that 1) their agent may someday be banned or severely restricted, or 2) and more importantly, that they may have inadvertently introduced a health hazard into the working environment.
What are my alternatives?
When Halon was banned, most large chemical companies that sought to manufacture a replacement looked to materials that were chemically similar to Halon. The idea was essentially to get as close to the banned substance as possible without crossing over into banned territory. Now, decades later, the push is for elimination of all risk associated with the PFAS chemical family.
The safer and more environmentally sustainable alternatives to HFCs and PFAS chemicals for use in special hazard fire protection applications today are:
Aerosols are a fine particulate matter discharged from modular canisters that are highly effective at chemical interruption of a fire’s chain reaction. Aerosols are typically cost effective and safe for use in occupied spaces.
Water mist is a fire suppression system using low quantities of water (compared to traditional sprinkler systems), discharged at high pressure, producing small droplets with large surface area. Water mist systems typically require a bank of high-pressure gas or large pumps to discharge the water through stainless steel tubing and nozzles.
Inert gas systems (typically nitrogen, argon, or a mixture of the two) require a large footprint of pressurized containers that, when discharged, reduce oxygen in the protected space sufficient to suppress or extinguish a fire
Over the past twenty-five years, environmental and public health concerns have resulted in the banning or restriction of several fire suppression agents. Despite the commercial impact, this is a step in the right direction. Agents that are designed to protect life and property should never themselves be a threat to public health or the environment.
Users of clean agent fire protection systems should review their options, understand the inherent risks of using either HFC’s or PFAS chemicals, and know that there are cost effective alternatives to achieve near identical fire protection performance.
- Proposed Rule - Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (epa.gov)
- EPA: GenX far more toxic that originally thought, could prompt NC to significantly reduce health advisory goal | NC Policy Watch
The content & opinions in this article are the author’s and do not necessarily represent the views of AltEnergyMag
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