Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

My name is Merriwa WA 6030. I served in the Royal Australian Air Force (RAAF) from 1975 to 1995 as a firefighter and I hereby formerly advise that I am making this submission to the Senate Inquiry into the Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia.

I wish to provide a submission to part B of the Senate Inquiry (By 30 April 2016 on PFOS and PFOA contamination on other Commonwealth, state and territory sites in Australia where firefighting foams containing PFOS and PFOA were used).

Specifically I wish to address the following aspects of the Terms of Reference (TOR):

i. what Commonwealth, state and territory facilities have been identified as having PFOS/PFOA contamination, and what facilities may potentially still be identified as being contaminated;

iii. what measures have been taken by the Commonwealth and state and territory governments, to ensure the health, wellbeing and safety of people in close proximity to known affected sites,

iv. the adequacy of public disclosure of information about PFOS/PFOA contamination,

vi. the adequacy of Commonwealth and state and territory government environmental and human health standards and legislation, with specific reference to PFOS/PFOA contamination, and

viii. any other related matters.

What Commonwealth, state and territory facilities have been identified as having PFOS/PFOA contamination, and what facilities may potentially still be identified as being contaminated:

During my service career I served at the following RAAF bases and can confirm that from the late 1970’s RAAF firefighters used Aqueous Film Forming Foam (AFFF) - Light Water supplied by the 3M Company. The introduction and ongoing use of AFFF generally coincided with the commissioning of new P4 aircraft firefighting appliances at these bases:

 RAAF Base Amberley  RAAF Base Darwin;  RAAF Base Edinburgh  RAAF Base Laverton  RAAF Base Pearce  RAAF Base Point Cook

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Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

While it is my belief that every RAAF Base is like to have contamination from AFFF, I can assure the Senate Inquiry that AFFF was used extensively at each of these bases in particular the areas that were designated the current and former fire training areas, fire sections (station) and its immediate area, fuel farms and fire appliance maintenance facilities. I especially mention appliance maintenance facilities because; if the mechanical fitters needed to access or dismantle any components of the appliance foam system they would often dump foam into the drain system.

Additional to the above, I suggest the following may also be a source of contamination:

RAAF Darwin:  (lonlat -12.419761 130.859272) I believe this was the old RAAF Fire Section

 (lonlat -12. 401701 130.859272) I believe this was close to an old fire training ground, possibly undesignated at the time.

RAAF Laverton:

 Close proximity to what was known as the Officer Commanding’s duck pond. An old aircraft was burnt there and extinguished with AFFF and then buried.

 Behind the old air traffic control tower. This was and undesignated fire training ground.

 Area designated the gun butts. This was used regularly for fire training with flammable liquids which were extinguished with AFFF.

RAAF Edinburgh:

 (lonlat -34.719368 138.616059) Old sewage treatment plant was used extensively as an undesignated fire training ground.

What measures have been taken by the Commonwealth and state and territory governments, to ensure the health, wellbeing and safety of people in close proximity to known affected sites?

Based on media reporting and indeed comments from the Member for Port Stephens, Kate Washington MP, I’d say the Federal Government, Department of Defence (DoD) and other Government Departments that have jurisdictional areas of responsibility have been less than forth coming in regards to disclosing the extent of contamination. If people are not being told about possible or confirmed contamination then how could the Government possibly claim acceptable measures are being taken to ensure the health, wellbeing and safety of people in close proximity of know affected sites. Additionally, the media has reported residents from around RAAF Williamtown are being refused tests to determine if they have elevated P a g e | 2

Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

levels of PFOS and PFOA1. If this is true how is this ensuring their health, wellbeing and safety? Irrespective of any physiological adverse health outcome they must be suffering from psychological stress for not knowing.

Land development appears to be continuing unabated around what was RAAF Bases Laverton, Point Cook and adjacent to Edinburgh and Darwin. I have kept a close eye on what is happening in and around the Pearce base in Western Australia and apart from some scant reports through print media there seems to have been minimal, if any, consultation with residents surrounding Pearce. Of additional concern for me, is the close proximity of the Gnangara water mound. The Gnangara system is the largest single source of good quality fresh drinking water in the Perth region and is of vital importance to Perth’s continuing social and economic development2. If a contamination similar to those being experienced at RAAF Williamtown or Oakey Army bases were to be identified at RAAF Pearce it could have dire consequences to Perth’s drinking water. Further, the run off from the base flows through a series of drain systems into Ellenbrook which eventually flows into the Swan River. Just what is being done to test not only for AFFF contamination but any other form of contamination downstream of RAAF Pearce?

When Senate Enquiry makes reference health and safety to people, will that include current and retired Defence Firefighters as well? Navy, Army and Air Force firefighter personnel have all had direct contact with this product in the pure and unadulterated state. The original Material Safety Data Sheet (MSDS) for AFFF that was issued prior to 2006 did not include anywhere near the same amount of safety information that is presented in the latest version issued in 2006. Interestingly, the current version of the MSDS appears to have no reference at all of any superseded versions, usually one would expect a list of the previous version numbers and issue dates.

The adequacy of public disclosure of information about PFOS/PFOA contamination

I and many of my of my former colleagues are exceptionally disappointed that there has been no effort on the part of the DoD through the Department of Veteran Affairs (DVA) to contact former Defence Force Firefighters informing them of the possible affects from AFFF contamination and making an offer to test for PFOS and related chemicals (incl. PFOA and PFHxS. If the anecdotal evidence is correct and there is a health, wellbeing and safety risk to people through indirect contamination from AFFF3, then arguably the individuals who were in direct contact with AFFF on almost a daily basis would be at much greater risk of having some signs of AFFF contamination but nobody seems to care about us!

1 Cronshaw, D. 8 Oct 2015 Newcastle Herald Toxic Truth: Blood Test Requests Denied 2 Government of Western Australia Department of Water Gnangara Groundwater Areas Allocation Plan – Water Resource Allocation and Planning Series Report #30 November 2009 3 Remeikis, A. 01 Oct 2015 The Other Towns Fearing RAAF Contamination – Newcastle Herald P a g e | 3

Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

When first introduced, firefighters were told AFFF was simply “nothing more than a highly concentrated detergent which lowered the surface tension so that it spread over the surface of flammable liquids forming a very thin, vapour sealing film that then deprived a fire of oxygen thereby smothering the fire”. Additionally, unlike the protein foam it replaced, the vapour sealing film barrier produced by the AFFF would immediately reform if it was broken, for example when firefighters walked through an aircraft crash site to conduct a rescue after the AFFF had been deployed to prevent or extinguish fire4. This characteristic of AFFF significantly reduced the potential for a flashover which is the sudden, unpredicted, violent re-ignition of the fire, which can have catastrophic consequences for firefighters, aircrew and passengers alike.

As former RAAF firefighter I can attest that my former colleagues and I were in directly bodily contact with AFFF during almost every shift that we undertook during our service career.

It was a requirement for firefighters to test the serviceability and the proper functioning of the firefighting appliances on every shift changeover; this included conducting a foam test. At the conclusion of the testing there was a need to clear the appliance’s foam making system of residual foam. This entailed draining the residual AFFF from the system, generally into 20 litre buckets, and passing the buckets up to a colleague on top of the appliance so it could be tipped back into the appliance’s foam tank. Accidental spillages occurred on many occasions which resulted in the firefighter’s skin coming into direct contact with AFFF. There was also times when firefighter’s clothing became contaminated with AFFF, more often than not it was simply washed off with a garden hose or left to dry. This contributed to indirect AFFF contamination of the firefighter and, possibly led to AFFF contamination being introduced into the family home when the clothing was washed.

Separate to the possibility of being contaminated by AFFF during the normal testing requirements of appliances, firefighers where further exposed to AFFF when they routinely participate in hot fire training exercises. This involved burning a veritable cocktail of flammable liquids in an effort to simulate aircraft crashes which were subsequently extinguished by the application of AFFF. The initial knock down was achieved using the appliance foam monitor system (sometimes referred to as foam canons) however, complete extinguishment could only be guaranteed by firefighters using fire hoses during overhaul of the fire area. This activity invariably resulted in firefighters becoming contaminated with AFFF, as well as the flammable liquids that were being used to fuel the fires in the first place.

Another activity that had the potential of firefighters coming into direct contact with AFFF was when they serviced AFFF stored pressure fire extinguishers. This entailed decanting AFFF from a bulk supply into the extinguisher to a predetermined level and pressurising the extinguisher with air from a compressor. Again this often resulted if direct skin contact with AFFF.

4 Colville, S. et al. Environmental Issue Associated with Defence Use of Aqueous Film Forming Foam (AFFF) May 2003 P a g e | 4

Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

I believe at this point I should also highlight the level protective clothing and equipment that was available during my service career is in no way comparable to what is available today. For example, at best, there was only two set of Breathing Apparatus (BA) available to a firefighting crew of six or more depending on the airfield category. The BA was intended to be predominately used at structure fires or Hazardous Material (HAZMAT) incidents and there was no such thing as particle masks at the time so our respiratory system was completely and utterly vulnerable. The firefighter boots we wore were made of leather which soaked up liquids as we walked through it, furthermore they were an open style boot similar in appearance to rubber garden boots so if the fire area was particularly deep in any part substances could enter the boot regardless of whether rolled our trousers legs over them or not but in general they were tucked in. The firefighting coats we were provided with did not comply with any relevant Australian Standards and specifically, rated for firefighting. In hindsight, I think we could say we were poorly equipped in respect to personal protective clothing and equipment.

Ironically, in the early stages of the introduction of AFFF into the RAAF, firefighters were encouraged to run their hand through the remnant liquids of an extinguished flammable liquid fire (in this case, usually methylated spirits) in an endeavour to bolster firefighter confidence in the capabilities of AFFF. This was especially so for firefighters who’d been in the service some time and long been use to the properties of the superseded protein foam, the exercise was supposed to let us see for ourselves how the film forming properties of AFFF would reform and stop flashovers.

Any other related matters

In this section of my submission I wish to comment on two points that I believe can fall under the Senate Enquiry’s TOR.

1. During my service with the RAAF as a firefighter we burnt large quantities of flammable trade waste products generated from within the DoD but by far, much more that was delivered from the private sector. I am more than willing as are many of my former colleagues to testify under oath that we witnessed tanker after tanker, truck after truck arrive at RAAF Bases Laverton and Point Cook from Victoria’s Altona industrial area for the purpose of dumping off industrial flammable trade waste either directly into practice fire pits or in 44 gallon drums. Drums were also transported by DoD to Victoria’s Country Fire Authority’s Fiskville training facility where it was set alight when DoD firefighers trained there.

Most of the waste products were unidentified but they burnt furiously and sent massive plumes of black smoke into the air. I recall one instance where after walking through the waste the hard rubber soles of my firefighter boots were more like sponge rubber. This was not an isolated instance at Laverton, the frequency of hot fire practices like this happened on almost every shift for the entire time I was at the base, and the quantity of flammable liquids available to burn was never an issue. At

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Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

Point Cook the frequency of hot fire training using these flammable liquids was even greater because of the additional training being carried out by the trainee firefighters going through the fire school. I believe it has been documented by DoD that during the redevelopment of Point Cook into residential sites approximately 200 (two hundred) chemicals were found to have contaminated the soil5. The cost of remediation works was around $27m

I firmly believe it is critical that the Senate Enquiry also consider the human and environmental impact of not only the AFFF that was used to extinguish these flammable liquid fires, but also the flammable liquids themselves and any by- products that have resulted through the mixing of all these chemicals.

2. A very large number of former Defence Firefighters and I have concern for our health, safety and wellbeing. Delegate representing retired DoD firefighters have met with current and former senior front bench politicians, DVA representatives and very highly ranked DoD Commissioned Officers to convey concerns we have about our health and wellbeing as a consequence of our service. They were given an assurance these would be thoroughly investigated, unfortunately what we got was abysmal.

The DoD will enthusiastically put before the enquiry the findings of the Defence Firefighter’s Health Study that was carried out by the Monash University6 in an effort to dispel the concerns however, I and a very large number of former Defence firefighters believe the finding of the report does not in any way deliver what we were led to believe it would, that is a comprehensive review into the health and wellbeing of former Defence Force firefighters. We do not in any way wish to criticize the authors; they were simply guided by their TOR.

I believe the main issue is that the DoD decided the most economical way to satisfy our collective call for a review into our health and wellbeing was to piggy back onto a study which had been commissioned by the Australasian Fire Authorities Council (AFAC), which had in fact already commenced.

Furthermore, we firmly believe the TOR for the Monash study was ultimately the catalyst for a report with limited data that truly reflects with any depth the actual health, safety and wellbeing status of former Defence Force firefighters.

The report in fact specifically states “This cohort group is young and small and relatively few cancers were found, resulting in low statistical power to identify any excess risks of cancer”.

Foremost to keep in mind when considering the finding of this report is that it was based on analysing the instance of cancer related disease and mortality rates they were related to in a number of cancers. The research group used the Australian

5 Guidotti, Tee, L Health Risks and Occupation as a Firefighter 28 February 2014 6 Simms, M. et al. Defence Firefighters’ health Study – Monash University April 2015 P a g e | 6

Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

Cancer Database (ACD) and National Death Index (NDI) or, where a death was subject to a coronial enquiry, the National Coronial Information Service (NCIS). Unfortunately the ACD and NDI were not in place until the 1980’s therefore the report was unable to include 332 (three hundred and thirty two) firefighters who had completed their service before 01 January 1980. Because these firefighters were excluded the risks to firefighters is likely to be under estimated7. Furthermore the report states the power of study was limited to very small numbers and the mean age of cohort group at the end of the study was only 45 years. Most types of cancer are primarily diseases of old age and most deaths occur later than this.

Despite the study cohort excluding 332 (three hundred and thirty two) firefighters there is an increase in the instances of cancers than what was expected (O = observed – E = expected). See table 6 extracted from8

Table 6

From an RAAF perspective the total number of unique individual records provided for the study was 1574 (one thousand five hundred and seventy four) 924 (nine hundred and twenty four) were included in the study9. This means that a total of 650 (six hundred and fifty) of its members were excluded or in percentage terms, 41.2% missed the cut!

Interestingly, throughout the report it was noted that a large number of records were incomplete e.g. they were missing a date of birth or some other detail. I am amazed

7 Simms, M. et al. Defence Firefighters’ health Study – Monash University April 2015 8 Simms, M. et al. Defence Firefighters’ health Study – Monash University April 2015 9 Simms, M. et al. Defence Firefighters’ health Study – Monash University April 2015 P a g e | 7

Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

to read this given the DoD supposedly kept accurate individual personnel records. Our service numbers, our names and dates of birth were routinely collected on almost every record we completed while we were in the services. I am unaware of any former colleague who has not been able to obtain a copy of the medical records. DoD and DVA must have these records because most of us have Defence Superannuation and many have applied for health services through DVA to which we’ve had to provide all the information that was supposedly missing.

When reviewing the Monash report its important to take into account that there is now a far greater emphasis and understanding of contemporary Occupation Health and Safety (OH&S) practices within Defence, including the development of policies and standards10. In my era of service safety measures and information on the chemicals that were used was limited, non-existent or simply portrayed as “safe” by the companies supplying the products, this is especially so for AFFF.

The firefighters that were involved in the Monash study have had the benefit of a heightened culture of OH&S awareness compared to what was the norm for their predecessors. They also have a far better understanding of the safe handling and storage of chemicals, including firefighting agents as opposed to many retired firefighters11. It cannot be over stated that current firefighters undoubtedly have superior levels of and access to the Personal Protective Equipment (PPE) that’s required when handling these products in comparison that what available to retired firefighters. It is likely that none of the PPE they had access to would satisfy the certification criteria as Protective Clothing for Firefighters12.

Most significantly though, is the cohort group that were not included in the Monash study are the very people that are most at risk. The majority of them are 60+ years old, they provided many years of service in the various arms of the DoD and unfortunately many are presenting with various health issues that have taken years to manifest.

10 Department of Defence Aqueous Film Forming Foam (AFFF) Procurement and Usage Interim Policy Version 1.0; August 2008 11 Colville, S. et al. Environmental Issue Associated with Defence Use of Aqueous Film Forming Foam (AFFF) May 2003

12 Australian/New Zealand Standards (AS/NZS) 4967: 2009 - Protective Clothing for Firefighters. P a g e | 8

Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

Conclusion

I firmly believe the extent of AFFF contamination across defence estates is far greater than what has already been identified. AFFF was extensively used by DoD firefighters but more particularly at bases with airfields. These would normally be identified as current and former RAAF bases.

From my point of view, it appears there has been very little done to investigate just how far any PFOS/PFOA contamination may have extended beyond the boundaries of the military bases where AFFF was either used or stored. There is a very distinct possibility that large amounts of AFFF would make its way into the base drainage systems and waterways and then flow downstream from these bases. Due diligence would dictate all interconnecting water courses and groundwater water supplies must be checked to ascertain whether they have been adversely affected or contaminated.

I am of the belief the Government and DoD have been less than forthcoming in respect to providing information to those who’ve possibly been affected or indeed contaminated by handling or using AFFF, including current and former members from the various arms of the Defence Forces, and in particular personnel whose primary duty was as a firefighter for it was they who used AFFF regularly.

If the Defence Firefighters’ health Study conducted by the Monash University dated April 2015 is to be used for reference, it should be done with a clear understanding that it is somewhat limited in its findings. This has come about because the data has been derived from a relatively young and small cohort study group. A significant number of retired DoD firefighters were excluded from the study on the basis that their service records were either incomplete of not available. The power of the study would have been far greater if their statistical information had been included. Be that as it may, the study and report was based around cancer and mortality rates therefore it fell well short of the expectations of held by many retired DoD freighters, who were expecting a wide ranging study into the health, safety and wellbeing of current and former DoD firefighters.

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Senate Inquiry - Submission into Contamination of Australia's Defence Force facilities and other Commonwealth, state and territory sites in Australia by

References:

Cronshaw, D. 8 Oct 2015 Newcastle Herald Toxic Truth: Blood Test Requests Denied

Government of Western Australia Department of Water Gnangara Groundwater Areas Allocation Plan – Water Resource Allocation and Planning Series Report #30 November 2009

Remeikis, A. 01 Oct 2015 The Other Towns Fearing RAAF Contamination – Newcastle Herald

Guidotti, Tee, L Health Risks and Occupation as a Firefighter 28 February 2014

Simms, M. et al. Defence Firefighters’ health Study – Monash University April 2015

Department of Defence Aqueous Film Forming Foam (AFFF) Procurement and Usage Interim Policy Version 1.0; August 2008

Colville, S. et al. Environmental Issue Associated with Defence Use of Aqueous Film Forming Foam (AFFF) May 2003

Australian/New Zealand Standards (AS/NZS) 4967: 2009 - Protective Clothing for Firefighters. (note this reference was not able to be submitted. It should be available through the Government Publisher)

Signed this day 01 Feb 2016

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