Per- and Polyfluoroalkyl Substances (PFAS) are a group of manufactured chemicals that have been used in industry and consumer products since the 1940s. Many organizations worldwide mandate the use of firefighting foam that contains PFAS, known as Aqueous Film Forming Foam (AFFF), because of its effectiveness in fighting aircraft fires. However, per the Environmental Protection Agency (EPA), certain PFAS can cause serious health problems, including cancer, if people are exposed to them over a long period of time, and they can also be harmful to aquatic and terrestrial organisms. As a result, the FAA and the Department of Defense (DoD) have engaged in a significant research project to test fluorine-free foam (F3).
In December 2022, Congress directed the FAA to prepare a transition plan to ensure an orderly move to MILSPEC F3 for aircraft firefighting. The following plan was coordinated with DoD, the Environmental Protection Agency, and industry partners: FAA Aircraft FireFighting Foam Transition Plan
In January 2023, DoD published an F3 military specification (MILSPEC), and foam manufacturers can submit MILSPEC F3 agents for qualification by DoD.
Once DoD certifies that a foam meets the new specification, it will be added to the Qualified Product List. FAA considers foams on the Qualified Product List as acceptable to use to satisfy the regulatory requirements of Part 139.
Both agencies have made clear that these minimum requirements only apply to DOD, not airports certified under Part 139.
The Department of Defense (DOD) and the Federal Aviation Administration (FAA) have issued additional guidance on how to make the transition away from PFAS-containing products. This is in response to the DOD providing their first round of fluorine-free firefighting product (F3) approvals.
As the DOD now transitions from Fluorinated Aqueous Film-forming Foams (AFFFs) to recently approved fluorine-free alternatives, it will remove AFFF from mobile assets including tanks, hoses and components using the following procedure:
- Completely drain the system of AFFF – F3 and AFFF MUST NOT BE MIXED.
- Conduct a single water rinse of the entire system from the AFFF tank through all components and piping to all discharge nozzles, including external equipment that previously contained AFFF.
- Empty rinsate from the system and reconfigure it for the selected F3 agent in accordance with the F3 manufacturer’s recommendations.
- Ensure appropriate spill prevention measures and containment are incorporated into the process to minimize any releases or impacts.
There is also detailed guidance on how to dispose of any rinsate and other AFFF-impacted materials, according to an earlier memo released last year:
FAA Points of Contact:
Tony Butters, AAS-310
202-267-9616
Email: anthony.butters@faa.gov
Jim Price, AAS-310
202-267-9085
Email: jim.price@faa.gov
Additional FAA Guidance
- Part 139 CertAlert 23-07: Availability of Fluorine Free Foam (F3) on the Navy’s Qualified Products List (QPL)
- Part 139 CertAlert 23-01: New Military Specification for Performance-Based Standards for Fluorine-Free Aircraft Fire Fighting Foam
Related Information
- Part 139 CertAlert 24-04: Information on Best Practices for Cleaning Aircraft Rescue Firefighting (ARFF) Vehicles Transitioning from Aqueous Film Forming Foam (AFFF) to Fluorine-Free Foam (F3) – includes DOD Memorandum: Guidance for the Change Out from Aqueous Film Forming Foam in Mobile Firefighting Systems
- Department of Defense (DoD) Qualified Products for MIL-PRF-32725
- Evaluation of Effects from Mixing Fluorine-Free Foam Concentrates (DOT/FAA/TC-TN23/73)
- Fluorine-Free Foam Fire Tests Using Various Foam Delivery Configurations (DOT/FAA/TC-TN23/60)
- Fluorine-Free Foam Testing (DOT/FAA/TC-22/23)
- Fluorine-Free Foam (F3) Application Techniques and Firefighting Tactics (dtic.mil) (PDF)