Making the transition from a PFAS containing foam system to SFFF
Fomtec decided some months back to adopt the “SFFF” which stands for Synthetic Fluorine Free Foam following the adoption by NFPA (in their 2021 edition of NFPA 11) and also by FM (as indicated in their latest edition of FM 5130). In this article we also wanted to use the umbrella term of PFAS containing whilst noting that depending on where a facility is located different regulations may apply depending on whether the firefighting foam is “C8” or “C6” as many of the considerations relating to making the transition to SFFF are the same whether the existing foam is C8 or C6.
C8 or C6 ?
Understanding what foam you currently have in the system does make a major difference to the urgency you as an end user need to be be aware of when planning the transition. This all comes back to where you are located and the legislative regulations that are being applied for various PFAS chemicals. In the US, state by state regulations are being introduced restricting the use of PFAS containing firefighting foams – with no derogation to whether or not the foam is C6 ! In Europe and the UK it’s different as since 2017 and EU 2017/1000 and the subsequent amendments / additions of 2019 and 2020 we have legal restrictions and deadlines on the use of PFOA – in effect our C8 foams. This current legislation prohibits the use of the C8 foams for anything other than firefighting (No training and no testing), and from January 1st 2023, only if you can contain the discharge. The extension where discharge can be contained is until July 4th 2025.
Unfortunately for those end users who purchased C6 foam after 2015, or who maybe in the process of specifying a system today legislation is expected this year which will restrict production and use of a chemical PFHxA, which will encompass the C6 foams ! With the document still in draft we can only speculate on the time line for the possible restriction of use of C6 foams, but additionally we should consider whether fluorosurfactants will be available due to the way regulations are proposed limiting and possibly cutting off the supply of fluorosurfactants to the foam manufacturers located in Europe!
So what are the considerations when making the transition to SFFF ?
Below are a sample of the questions / concerns that have been raised by clients who have already completed or are starting their planning process for the transition:
- What are my legal obligations?
- What type of (PFAS version) foam concentrate do I have?
- Do I need to be concerned with PFAS regulation if discharges are captured and processed?
- What does drop in replacement mean?
- Is there a different impact between new installations and existing?
- I need to follow NFPA, FM design standards. What impact does that have?
- Can I use the existing discharge device density?
- Can I use the existing pump and water supply capacity?
- Can I use my current proportioning system?
- Can I keep my existing discharge devices?
- Do I need to clean the system pipework and how clean is clean?