Industrial Fire Journal - Fire & Rescue - Hemming Group Ltd
Queensland publishes new operational policy for firefighting foam
Published:  11 July, 2016

Highly restrictive environmental management requirements effectively ban aqueous film-forming foam (AFFF).

The Department of Environmental and Heritage Protection of the state of Queensland, Australia has published its long-awaited operational policy on the environmental management of firefighting foam.

The new policy outlines the requirements for the handling, transport, storage, use, release, waste treatment, disposal and environmental protection measures around firefighting foam in Queensland.

Minister for Environment and Heritage Protection and Minister for National Parks and the Great Barrier Reef, Dr Steven Miles (pictured above) said: “Queensland is adamant that firefighting foams containing highly persistent organic pollutants including perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) implicated in the contamination of the Oakey Defence base need to be phased out.

“The Government will require that any existing stocks of foams containing PFOS and PFOA are withdrawn from service at commercial and industrial premises, and similar products phased out and replaced, as soon as practicable with more sustainable alternatives.”

Situated in the north-east of the country, Queensland is the second-largest state in Australia and is home to six World Heritage-listed preservation areas including the Great Barrier Reef. The state has a large coal, mineral and gas resource base with a modest scale chemical industry.

According to a media statement by the Queensland Government, the impact of the ban will be felt by a small number of industry sectors in Queensland that continue to hold stocks of PFOS and PFOA foams for use in emergency situations, such as industrial ports and bulk fuel storage facilities.

“Our focus is on those who hold large stocks of toxic firefighting foam for use in an emergency situation, as they have the potential to cause significant environmental harm, if used,” Dr Miles said.

Large stocks of PFOS foam are known to be held throughout Australia despite the current knowledge around PFOS’s adverse effects. The policy document highlights an incident involving a one-tonne spill of PFOS-containing foam that occurred in Queensland into a body of water connected to the Great Barrier Reef Marine Park in January 2013.

The policy outlines that foams containing C6 can still be used for firefighting operations when they are the only viable option and if they meet a number of strict requirements. There can be no releases of C6 foams directly to the environment – for example uncontrolled drains or soakage pits – and all releases must be fully contained on site.

Significantly, only C6 foam that is ‘purity-compliant’ can now be deployed in the state. For foam concentrates to meet this requirement they must not contain more than 50 parts per million of PFOA and PFOA precursors, says the report. Companies that hold stock of foam above this limit must prepare a disposal plan for it in the next six months.

Although the new policy’s comprehensive explanatory notes acknowledge that C6 foams are now widely available as alternatives to more bioaccumulative, longer-chain compounds, they point out that significant concerns are emerging about all PFCs – including short-chain compounds (i.e. C6 and below). A degradation endpoint compound for new-generation C6 foams is perfluorohexanoic acid, which is reported to be three to five times more acutely toxic than PFOA for some aquatic species.

In addition, the notes point out that there is still insufficient independent information publicly available on C6-based or C6-pure foams to conduct realistic environmental risk assessments due to major gaps in information.

The policy has not been welcomed by the fire industry. Fire Protection Association Australia has voiced concerns regarding the consultation and implementation process of the policy, in particular the lack of transitional mechanisms for existing users of now banned foams to move to fluorine-free alternatives. These concerns have been supported by the US-based Fire Fighting Foam Coalition, a not-for-profit industry association.

FPA Australia has also said that it was deeply concerned by the Queensland Government’s view that potential environmental impacts alone should determine foam selection and use.

Matthew Wright, Chief Technical Officer/Deputy CEO of FPA Australia said the ban was a simplistic response to a complex issue and that it could be potentially dangerous.  “Environmental impacts must be a key consideration in the selection and use of firefighting foams, but this policy naively ignores the new generation of short chain ≤C6 fluorinated foams which are non-toxic and non bioaccumulative and simply draws an unrealistic line between fluorine-free and fluorinated foams as the deciding factor for selection,” he said.

“If a foam is not effective for the hazard, the environmental impact will be magnified by the persistence and potential escalation of the fire event itself, damaging smoke, and potentially carcinogenic products and runoff regardless of whether the foam is fluorine free or not,” said Wright.

The Environment Dr Miles however has pointed out that Queensland Fire and Emergency Service has been using PFC-free firefighting foam since 2003. “Non-persistent firefighting foams are available, effective and certified for all major firefighting applications. They can break down or biodegrade should they be released to the environment.”

The Association is calling on the Queensland government to suspend implementation of the policy and to work with industry to develop alternative transitional arrangements.

The Environment Minister has said that over the coming months the government will work with ports and bulk fuel storage facilities to ensure they fully understand the government’s new strict policy: “Businesses failing to comply with the policy to replace such stocks will face enforcement action. Businesses that supply or replenish portable extinguishers will also need to comply with the policy.”

Dr Miles has also clarified that contamination caused by the historical use of these firefighting foams during training exercises at a range of facilities, including defence bases and airports, was largely the responsibility of the users such as the Department of Defence and Commonwealth Government.

You can download the policy below. To download the comprehensive explanatory notes, click here.