The current situation?
The UK Government is continuing to meet its commitment to phase out the use of PFOAs from firefighting products. PFOAs are known as “forever chemicals” due to their lasting harmful impact on the environment.
This phase out is being achieved through measures restricting or prohibiting the manufacture, placing on the market and use of PFOA, its salts and PFOA-related compounds used in fire-fighting foam for liquid fuel vapour suppression and Class B fires. It will include the use of aqueous film forming foams (AFFF) fire extinguishers.
What are “forever chemicals”?
“Forever chemicals” have been widely used across the world since the 1940s, from fire-fighting foams to industrial applications and consumer products. Their high thermal and chemical stability and water and oil-repellent nature means they have been heavily used in cosmetics, coatings for textiles and paper including food contact materials.
They comprise per and polyfluoroalkyl substances (PFAS) which is the collective name given to a group of fluorinated compounds.
PFAS are everywhere in nature due to their inability to break down. The long history of their use has resulted in “a legacy of environmental contamination that is challenging to remediate”, according to the Environment Agency, and their toxic nature has been linked to health problems since the 1990s. They are a large group of synthetic, environmentally persistent and potentially toxic chemicals, which can build up in living organisms through a process called bioaccumulation.
The best-known examples of PFAS are PFOAs and perfluorooctane sulfonate (PFOS), both of which are now subject to regulatory restrictions because of their harmful properties.
What legislation do you need to know?
Assimilated Regulation 2019/1021 on persistent organic pollutants (the UK POPs Regulation) bans the production, placing on the market and use of substances, mixtures and articles containing PFOA, its salts and PFOA-related compounds.
They have previously been used as active ingredients in Class B firefighting foams, and particularly so within AFFFs, in the main due to their surfactant properties. They may also be present in foams as a contaminant.
Exemptions and deadlines?
There was a recent restriction from 1 January 2023, where the use of the fire-fighting foam was only allowed in sites where all releases can be contained.
The use of PFOA, its salts and PFOA-related compounds in firefighting foams for Class B fires will be banned on the 4th of July 2025.
What you need to do?
Assess your current fire safety equipment and plan for the switch to safer alternatives. It is essential that you find out whether the foam in your extinguishers contains PFOA, its salts and/or PFOA-related compounds.
You can do this by:
- checking the safety data sheet for the foam
- contacting the supplier or manufacturer of the foam
- getting the foam analysed by a suitable lab
If your fire extinguishers have been regularly serviced, refilled or replaced every five years, its likely they do not contain PFOS or PFOA.
However, if your extinguishers are very old with no service or refill record, then it should be assumed to be potentially containing PFOS or PFOA and environmentally disposed of.
In addition, if you intend to use, or have a stockpile of Class B foam already installed in systems which contains or may contain PFOA, its salts and/or PFOA-related compounds, you must comply with the following conditions –
- holders of stockpiles greater than 50kg must notify the appropriate regulator by completing a stockpile notification form, as soon as possible
- the fire-fighting foam must not be used for training
- the fire-fighting foam must not be used for testing unless all releases are contained
Written by Daniel Prosser, MSc CMIOSH L4DipFRA OSHCR
Safety, Health and Wellbeing Professional