manufacturers of the introduction of short-chain
fluorotelomer products means that the AFFF
industry is in position to meet the EPA goal well in
advance of the 2015 target date.
Fire Fighting Foam Coalition
In May 2001, AFFF and fluorosurfactant manufac-
turers met in Washington DC with representatives
of the US EPA, the US military, and major foam
users to discuss the
fallout from 3M's decision to stop production of
PFOS-based AFFF due to environmental concerns.
It quickly became clear that users and agency staff
did not fully understand the differences in chem-
istry between PFOS-based and fluorotelomer-
based AFFF agents. It was also evident that
speculation about the future regulation of AFFF
agents was causing problems for the industry. As a
result of this meeting, the Fire Fighting Foam
Coalition (FFFC) was formed to ensure
that accurate information about fluorotelomer-
based AFFF agents is disseminated to appropriate
audiences.
FFFC is a non-profit corporation that represents
the AFFF industry's interests on all issues related to
the environmental acceptability of fire fighting
foams. The coalition provides a focal point for
industry technical reviews, development of industry
positions, and interactions with the EPA and other
relevant organizations. Members of are AFFF
manufacturers, fluorosurfactant manufacturers,
and distributors.
FFFC has provided extensive information on
AFFF to environmental agencies in the US, Europe,
and Canada that includes the following:
Amount of fluorosurfactant actives used in the
manufacture of AFFF in the US
Chemical structure of the fluorosurfactants
used in major fluorotelomer-based AFFF
formulations
Mechanics of film formation
Groundwater monitoring data from US military
fire training areas
U.S. Inventory of PFOS-based and fluorotelomer-
based AFFF
Overview of the different types of foams, the
market channel for their distribution, and the
environmental fate once they are used
Aquatic toxicity of fire fighting foams
Existing stocks of PFOS foams
Although production of PFOS-based foams ended
in 2002, significant stocks of PFOS-based foams
are still in service in many industries throughout
the world. A study by Hughes Associates of AFFF
inventories in the US showed that there were
4.5 million gallons of PFOS-based AFFF concen-
trate in stock in 20045. While US regulations do
not restrict the use of these stocks, regulations in
Europe and Canada would ban the useof existing
stocks of PFOS-based foams within 3-5 years.
A European Union directive on PFOS was
published in December 2006 that requires existing
stocks of PFOS-based foams to be removed from
service by June 27, 2011. To facilitate tracking and
adherence to the directive, EU member states
must provide the European Commission with an
inventory of existing stocks of PFOS-based foam
agents by December 27, 2008.
A proposed regulation was published by
Environment Canada in December 2006 that
would requires existing stocks of PFOS-based AFFF
to be removed from service 5 years after the
regulation comes into force. During the 5-year
exemption period, those stocks could not be used
INTERNATIONAL FIRE PROTECTION 33
AFFF INDUSTRY IN POSITION TO EXCEED ENVIRONMENTAL GOALS
FIRE FIGHTING FOAM COALITION
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Telephone +49 (0) 40-73 61 68-0
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Telephone +49 (0) 35 01-46 44 84 + 52 40 06
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