Winter weather is here to stay for the next couple months, but that fluffy, white stuff leading the headlines in the aviation industry is not snow—it’s Aqueous Film Forming Foam (AFFF). Recently, two AFFF news stories have drawn industry attention to this other kind of “white stuff”: the recall of Fire Service Plus FireAde AFFF and a defense bill proposal for the United States Environmental Protection Agency (EPA) to designate substances used in AFFF as “hazardous materials”.
Recall of FireAde AFFF
On December 4, 2019 the Federal Aviation Administration (FAA) issued a recall of Fire Service Plus FireAde AFFF. After tests showed the product failed to extinguish fires within the required performance time, the FAA directed all airports using the FireAde to empty the product from their ARFF vehicles, remove it from their foam supply inventories and report their inventory to their FAA Airports Regional Manager.
Due to this recall, airports having this product needed to promptly find an approved replacement foam before they can allow air carrier operations. Some airports resorted to borrowing approved foams from other airports nearby. Furthering complicating matters, FireAde contains PFAS, which means disposing of it comes with additional regulations.
Defense Bill Proposal to Designate PFAS as a “Hazardous Material”
At the same time this recall was occurring, lawmakers were negotiating the National Defense Authorization Act, which included a provision requiring the EPA to designate the entire class of PFAS chemicals as “hazardous materials”. Although the congressional conference committee ultimately dropped the “hazardous substance” provision from the bill, it’s likely this issue will be revisited in future lawmaking. Since PFAS is required in firefighting foams used by airports, this designation would create operational and remediation challenges…or would it?
Designating PFAS as a hazardous material would force the EPA to define regulatory levels for soil and drinking water contamination. This would give airports specific defined criteria to determine if: 1) PFAS contamination found at their facilities is problematic or not, and 2) The acceptable concentration for PFAS, so they’d know how much contamination they’d need to clean up. Far from being the easier option, this lack of defined regulatory criteria for soil and groundwater has created challenges for airports investigating potential PFAS contamination at their facilities.
This is a time of flux for our industry. How has the FireAde foam recall affected your airport? How would designation of PFAS as a hazardous substance impact your airport? How can you properly dispose of the FireAde foam or any other PFAS-containing AFFF? How do you appropriately investigate potential PFAS contamination at your airport? These are just a few of the questions you may be asking yourself. By proactively addressing these issues, we can help airport clients across the nation survive and thrive well into the future.
