Document dnbg20m3Z2pZemapMJrOBxaGb

JFFFC \ Fire Fighting Foam Coalition 1001 / 9th Street North Suite 1200 Arlington, VA 22209 (571) 384-7915 Fax (571) 384-7959 cortinaec@cox.net www.fffc.org FACT SHEET ON AEFF FIRE FIGHTING AGENTS You may have heard recently about a potential environmental issue related to aqueous film forming foam (AFFF) fire fighting agents. You may have also heard that certain types of AFFF are no longer manufactured. The Fire Fighting Foam Coalition has produced this fact sheet to provide you with accurate, balanced information about this issue. Fluorinated Surfactants All AFFF fire fighting agents contain fluorinated surfactants (fluorosurfactants). They are key ingredients that provide AFFF with the required low surface tension (15 to 17 dynes/cm) and positive spreading coefficient that enables film formation on top o f lighter fuels. It is this film formation capability that gives AFFF its name and its effectiveness against flammable liquid fires. The chemicals used to produce fluorosurfactants can be manufactured by different processes and have different chemical structures. The fluorosurfactants used in AFFF have historically been produced from fluorochemicals manufactured by two methods: electrochem ical fluorination and telomerization. AFFF agents manufactured by 3M contain fluorosurfactants produced by electrochemical fluorination. Virtually all other AFFF agents contain fluorosurfactants produced by telomerization. PFOS In 2002, 3M voluntarily stopped production o f a number o f products including AFFF agents because they contain and degrade into perfluorooctane sulfonate (PFOS). PFOS is considered by environmental authorities to be persistent, bioaccumulative and toxic (PBT). Regulations in the United States, Canada, European Union, Australia, and Japan act as a ban on new production o f PFOS-based products including foams. These regulations do not currently restrict the use o f existing stocks o f PFOS-based foam in the US, Australia, or Japan. In the EU and Canada, existing stocks o f PFOS-based foam must be removed from service in 2011 and 2013, respectively. Production and sale o f PFOS foams continues in China. Telomers All modern AFFF agents (except some produced in China) contain telomer-based fluorosurfactants. Telomer-based AFFF agents do not contain or break down into PFOS and have about 30 - 60% less fluorine than PFOS-based AFFF. Telomer-based AFFF agents are not made with any chemicals that are currently considered by environmental authorities to be PBT. The US Environmental Protection Agency (EPA) has indicated that some telomer-based fluorochemicals can break down in the environment into perfluorooctanoic acid (PFOA) or other perfluorocarboxylic acids (PFCAs). Further, EPA states that their concern is focused on long-chain perfluorinated chemicals (LCPFCs) containing eight carbons or more (C8, Cio, C i2). Existing data shows that shorter-chain compounds (Q, and below) have a lower potential for toxicity and bioaccumulation. EPA PFOA Stewardship Program Under the EPA 2010/15 PFOA Stewardship Program eight fluorochemical manufacturers have voluntarily agreed to reduce by 95% by year-end 2010 and work to eliminate by year-end 2015 both plant emissions and US00007914 product content o f PFOA, PFOA precursors, and related higher homologue chemicals. EPA intends to propose a regulation in 2012 that would close any loop holes in the Stewardship Program such as treated article imports. EPA Program - Impact on AFFF The EPA Stewardship Program is focused on eliminat ing telomers with eight or more carbons (C8 or above). Historically, the majority o f the fluorosurfactants used in telomer-based AFFF have been derived from six-car bon molecules (Cg). Some current AFFF formulations contain over 90% pure Cg fluorosurfactants, but others contain a higher percentage o f C 8 and above. Over the next few years, AFFF manufacturers will be introducing reformulated products that contain only Cg fluorosurfactants. These new fluorosurfactants must be approved by EPA under the TSC A New Chemicals Program. There have been foam agents on the market for 25 years that contain more than 90% Cg fluorosur factants and meet the toughest industry specifications. This history makes manufacturers confident that the new products will retain the same fire suppression capabilities as existing agents. Changes to formulations may require products to be re-qualified under the various specifications such as U L and FM. AFFF Manufacturers What are AFFF manufacturers doing to address the environmental concerns about AFFF? AFFF manufac turers, in conjunction with fluorosurfactant manufac turers, have formed the Fire Fighting Foam Coalition Inc. (FFFC). The Board members o f FFFC are Ansul, Chemguard, DuPont, Dynax, Kidde, and Solberg. FFFC was formed to represent the fire fighting foam industry's interests on all issues related to the environ mental acceptability o f AFFF agents. The coalition provides a focal point for technical reviews, develop ment of industry positions, and interactions with relevant organizations such as environment agencies, militaries, and standards organizations. FFFC wills Support users o f AFFF by serving as a single source for accurate, balanced information on environment related questions. Establish a dialog with EPA and other regulatory authorities to ensure that they have accurate informa tion about the makeup and use o f fire fighting foams. Establish a dialog with the US Department o f Defense on technical and environmental issues related to AFFF agents. FFFC Membership Membership is open to any company or organization interested in AFFF-related issues including users, distributors, equipment manufacturers, agent manufac turers, surfactant manufacturers, and telomer producers. Membership and participation by AFFF users is encouraged. For more information please contact: Thomas A. Cortina Executive Director 571-384-7915 571-384-7959 (fax) cortinaec@cox. net Conclusions Telomer-based AFFF agents are the most effective agents currently available to fight flammable liquid fires in military, industrial, and municipal settings. They do not contain or breakdown into PFOS and are not likely to be a significant source o f LCPFCs. They do contain fluorosurfactants that are persistent, but are not generally considered to be environmental toxins. AFFF and fluorochemical manufacturers are in position to meet the goals o f the EPA PFOA Stewardship Program with a new family o f fluorosurfactants that provide the same fire protection characteristics with reduced environmental impacts. US00007915