In mid-September, two long-awaited actions paved the way for Part 139 certificated airports to finally be able to use fluorine-free foams (F3). This is part of the effort to eliminate future per- and poly-fluoroalkyl substances (PFAS) discharges into the environment from Aqueous Film-Forming Foam (AFFF) use. On September 13, 2023, the United States Department of Defense (US DoD) Qualified Products Database (QPD) certified the first F3 firefighting extinguishing agent liquid concentrate to meet the performance requirements of military specification MIL-PRF-32725. This first product is Solberg’s 3 percent MIL-SPEC Synthetic Fluorine-Free Foam (SFFF). At the time of this blog post’s publishing, this was the only F3 product certified on the QPD; however, additional certified F3 products are anticipated to be added by the end of 2023.
Shortly after the QPD was published, the Federal Aviation Administration (FAA) published CertAlert 23-07, which authorizes Part 139 airports to be able to use certified F3 products listed on the QPD to meet fire extinguishing agent requirements. The following operational factors need to be considered when planning to transition to F3:
- F3 products are not interchangeable – F3 products are compositionally different. Research has shown that, though they need to meet the same performance requirements, the mixing of F3 products can affect the effectiveness of their overall firefighting performance. Therefore, once an F3 product has been chosen, airports will not be able to mix together different F3 products if different F3 products are purchased in the future.
- Firefighting tactics and firefighter training may vary between products – As each F3 is compositionally different, the firefighting tactics used to achieve optimal performance of the foam may differ between products. Likewise, how firefighters are trained to use the F3 may also vary because of the F3 product used at an airport. This factor is important when transitioning to F3 as identification of proper training will be needed, pending the product chosen.
- Aircraft Rescue and Fire Fighting (ARFF) vehicle modifications needed for F3 use may vary between products – Overall, F3 concentrate has a different viscosity than AFFF; thus, modifications to foam systems on existing ARFF vehicles are needed to use F3. Additionally, due to the varying composition of F3 products, there can be differences in the types of modifications needed to existing ARFF vehicle foam systems based on the selected product. Coordination between ARFF vehicle and F3 manufacturers can help determine the foam system modifications needed to use a particular F3 product.
- When applied to a fire, AFFF and F3 can be used interchangeably – Research has shown that when AFFF and F3 are both applied to a fire, the mixing of extinguishing agents did not affect their effectiveness. This is an important consideration for airports that decide to not fully transition an entire ARFF vehicle fleet for F3 use.
- Additional F3 products are anticipated to be certified – As of the publishing of this blog, there was only one F3 product approved for use; however, as previously mentioned, it is anticipated that additional F3 products will be certified for use by the end of 2023. This is important for airports to consider when transitioning to F3 if there are challenges associated with product cost, resupply, training, and ARFF vehicle foam system modifications. This is in addition to airports that may need to have multiple F3 products on the market to meet bid procurement requirements.
Considering these operational factors, airports will be better positioned to transition to F3 to eliminate future PFAS releases associated with AFFF use. Airports are encouraged to continue to monitor F3 developments in their effort to transition to the use of these products, as well as continuing to coordinate with industry partners like ARFF vehicle and F3 manufacturers and the FAA.
