Fire Rescue Victoria
Update to MFB Submission to the PFAS Sub- committee of the Joint Standing Committee on Foreign Affairs, Defence and Trades
Fire Rescue Victoria (FRV), as the successor of the Metropolitan Fire and Emergency Services Board (MFB), welcomes the opportunity to provide this update to MFB’s previous submission to the Joint Standing Committee on Foreign Affairs, Defence and Trades (Committee).
In its previous 2018 submission, MFB addressed each of the Committee’s terms of reference and provided tangible examples of what MFB is doing that can be replicated to mitigate the impact of per- and polyfluoroalkyl substances (PFAS) contamination in and around work environments.
As in 2018, MFB strongly believes that the below examples of PFAS mitigation and decontamination work that it has undertaken will be useful to the Inquiry. MFB suggests that the current circumstances relating to PFAS will require leadership and clear communication. Given the measured success of MFB’s PFAS mitigation activities, it is well-placed to share its knowledge and experience in this context.
The below includes a progress report on a range of PFAS mitigation activities occurring across MFB staff and MFB property and surrounding neighbouring environments, that measure reductions of PFAS exposure or levels that MFB may have contributed to predominately from MFB’s historical use of PFAS containing fire fighting foam prior to 2009.
FRV also acknowledges that other partners in its various PFAS mitigation work may also provide their own submissions to the Committee on various projects in which they are involved.
FRV would be pleased to appear before the Committee to provide further information about the matters outlined in this update. FRV is available to provide further detail on request.
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Summary of below FRV response
Building on MFB’s legacy, FRV is a national leader in addressing PFAS legacy issues and will continue MFB’s work in developing and implementing a range of policies specific to address remediation of PFAS contaminated facilities and equipment. These include, but not limited to:
1. Policy to use only fluorine-free firefighting foam 2. Involvement in domestic and international PFAS related submissions/papers 3. Testing of PFAS levels of FRV operational firefighters and mechanical workshops staff 4. FRV / Macquarie University PFAS Clinical Research Pilot Study 5. FRV Fire Station PFAS Soil, Water and Fruit & Vegetable Testing 6. FRV Fire Station ‘Dust Safe’ Initiative 7. FRV’s PFAS Decontaminating process’ of FRV Appliances 8. FRV PFAS Threshold Limits 9. Victorian Emergency Management Training Complex (VEMTC) 10. Suggested legislative / regulatory updates 11. Adequacy of health advice and testing 12. 2018 PFAS National Environmental Management Plan 13. FRV operations at Victorian RAAF bases 14. Defence and Air Services Australia Visit
FRV Responses
1. FRV policy to use only fluorine-free firefighting foam
In 2007, MFB made a decision to replace existing firefighting foam with fluorine- free firefighting foam. This decision was on the basis of concerns relating to firefighter health and environmental issues. MFB then phased out the use of persistent PFAS-containing firefighting foams across its operations.
MFB developed and formally endorsed an ‘Operational Use of Firefighting Foam Policy’ (See attached Schedule 1), which was formally endorsed by the Environmental Protection Authority (EPA), WorkSafe and the Country Fire Authority (CFA). MFB developed this position in relation to the use of non-MFB approved foam concentrate at sites that include Commonwealth and Major Hazard Facilities and in MFB appliances.
During 2011, based on independent scientific studies into PFAS, that identified links to various cancers and other health concerns, MFB extensively trialled and
Fire Rescue Victoria evaluated various fluorine-free firefighting foam in hot fire, flammable liquid, B Class fire scenarios.
MFB found that the fluorine-free foam consistently performed well in extinguishing B Class fires and provided MFB firefighters with a proven 'safer' alternative extinguishing medium. This work provided MFB with an operational firefighting foam solution that could be effectively used at Department of Defence sites, such as RAAF Airbases at Point Cook and Laverton. This enables MFB and FRV to meet its obligations for the delivery of emergency services to Defence bases using firefighting foam that does not contain PFAS.
By 2014, all MFB firefighting appliances had been converted to only carry fluorine free B Class foam in their foam tanks.
2. MFB/FRV involvement in the preparation and review work on a range of domestic and international PFAS related submissions/papers
International studies indicate that there are significant adverse health impacts relating to PFAS, which are summarised below. FRV’s view is that there is a need for national leadership and coordination to advance the state of knowledge regarding PFAS in the Australian context. FRV urges consideration and appropriate funding of further effort in this area.
FRV formally endorses the precautionary principle approach to PFAS, based on a significant body of research findings, some of which is outlined below.
FRV senior management has played a leading part in advocacy and advising global decision makers as to the adverse health impacts of PFAS to firefighters.
This work has included the preparation and review work on a range of domestic and international PFAS related submissions/papers;
Submission to the 2018 The Joint Standing Committee on Foreign Affairs, Defence and Trades (Committee), Inquiry into the management of per- and polyfluoroalkyl substances (PFAS) contamination in and around Defence bases. (Including the repeated offers to present at this inquiry).
Submission to the Federal Department of Health’s Expert Panel for PFAS,
United Nations Stockholm Convention Persistent Organic Pollutants (COP9) (Geneva 29 April – 10 May 2019). o This included addressing the United Nations’ Stockholm Convention, on firefighters’ experience of PFAS exposure, contamination and the effects of PFAS and calling for a worldwide ban on the use of PFAS
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in firefighting foam. This was the first time a professional firefighter made a submission to the UN Stockholm Convention. This was supported by the International Federation of Fire Fighters (IAFF), the United Firefighters Union of Australia (UFUof A) and New Zealand Professional Firefighters Union (NZPFU).1 IPEN White Paper, ‘The Global PFAS Problem: Fluorine-Free Alternatives as Solutions’, UN Stockholm Convention Persistent Organic Pollutants (COP9) (Geneva 29 April – 10 May 2019) 2. UN Stockholm Convention Persistent Organic Pollutants Review Committee (Rome October 2019). IPEN White Paper, ‘Continuing Environmental Contamination with PFAS’, ‘The Case for No Exemptions or Acceptable Uses’. 14th Stockholm Convention Persistent Organic Pollutants Review Committee (Rome October 2019). 3 IPEN F3 Panel, 9th Stockholm Convention of the Parties (COP9): ‘A Doubtful Future for Short-Chain PFAS’ white paper. IAFF Redmond’s Symposium (Nashville USA, August 2019) European Chemicals Agency (‘ECHA’) PFASs in firefighting foams assessment research paper. The Australasian Fire and Emergency Service Authorities Council (AFAC) is the peak body for public sector fire, land management and emergency service organisations in Australia and New Zealand. AFAC 2019 Conference (Melbourne August 2019) (AFAC is the peak body for public sector fire, land management and emergency service organisations in Australia and New Zealand).
Further Background
In 2001 the Stockholm Convention ratified PFOS as a Persistent Organic Pollutant.
The United States Environment Protection Authority (US EPA), has listed PFOA and PFOS as chemicals known to cause reproductive toxicity. In 2000 the US EPA notified the Australian Government that PFOS is a "persistent, bio accumulative and toxic chemical”. The US EPA advised that 3M (the US manufacturer of PFOS) supplied it with data which indicated that PFOS chemicals are "very persistent in the environment, have a strong tendency to accumulate in human and animal tissues and, based on recent information, could potentially pose a risk to human health and the environment over the long term." PFOS "appears to combine Persistence, Bioaccumulation and Toxicity properties to an extraordinary degree.”
1 https://vimeo.com/333226212 2 https://ipen.org/documents/global-pfas-problem-fluorine-free-alternatives-solutions 3 https://ipen.org/sites/default/files/documents/the_global_pfas_problem-v1_5_final_18_april.pdf
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(see Schedule 2). This caution from the US EPA of the adverse health effects from PFAS is further reflected in 2017. 4
3M’s (PFOA manufacturer), own funded research concluded there is a “probable link” from PFAS exposure to six disease categories, (high cholesterol, ulcerative colitis, thyroid disease, testicular cancer, kidney cancer, and pregnancy induced hypertension).5 In a 2016 letter from 3M to an Australian Senate Foreign Affairs, Defence and Trade Reference Committee, 3M acknowledged that “probable link” means “more likely than not”.6
Recent test results from the October 2017 Large Atmospheric Storage Tank Fires (LASTFIRE) Foam Summit conference held in conjunction with the International Industrial Fire Chiefs Conference in Budapest, confirmed that fluorine-free B Class foam is equally effective as a firefighting medium for B Class fires, without the inherent long-term health and environmental risks.7
3. Testing of PFAS levels of FRV operational firefighters and mechanical workshops staff
In 2016 MFB commenced offering voluntary blood testing for its employees. Since blood screening began, over 640 MFB/FRV employees have been tested. MFB and FRV have determined that early blood testing provides; - Early identification - Early monitoring - Early intervention - Early recovery, from the six disease categories, (high cholesterol, ulcerative colitis, thyroid disease, testicular cancer, kidney cancer, and pregnancy induced hypertension), that 3M’s own research indicated.8
The screening has indicated that MFB/FRV employees have, on average, significantly higher PFAS readings in blood serum than the average Australian population. The results also confirmed that this exposure to PFAS is most likely due being employed by MFB/FRV9. As part of FRV’s Employee Health and Wellbeing programs, FRV’s voluntary employee blood testing provides for increased employee physical, mental and emotional health.
4 https://www.epa.gov/pfas/basic-information-pfas#healths 5 Refer: C8 Science Panel http://www.c8sciencepanel.org/prob_link.html 6 25/02/2016 3M letter to Australian Senate Foreign Affairs, Defence and Trade Reference Committee 7 Refer: http://www.lastfire.co.uk/refmatpapers.aspx?id=12 8 C8 Science Panel http://www.c8sciencepanel.org/prob_link.html 9 18/06/2018 MFB letter sent to all MFB Firefighters and Workshop Staff
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4. FRV / Macquarie University PFAS Clinical Research Pilot Study
The Victorian Government conducted the Parliamentary Inquiry into the Fiskville Training Centre in 2015. A recommendation from the Fiskville Interim Report was that the Victoria Government assesses the feasibility of providing voluntary testing for PFOS to firefighters.10
In 2019 MFB commissioned Macquarie University, Faculty of Medicine Science, as the academic partner with MFB to conduct a $1.2M Clinical Trial Study to research whether regular blood and/or plasma donations reduce PFAS levels in MFB firefighters’ blood. 11 This FRV/Macquarie University Clinical Trial Study is currently underway and involves the voluntary participation on over 275 FRV firefighters.
This FRV/Macquarie University Clinical Trial Study conducted by the Macquarie University School of Medicine includes fortnightly project reporting by a team of Macquarie University School of Medicine clinical team project specialists and a dedicated Advisory Panel that meet regularly made up of senior international PFAS specialists listed below;
- Doctor / Principal Investigator / Haematologist (Australian NSW based) - Professor / Faculty of Science & Engineering (Australian based) - Professor / Environmental Health, PFAS expert (Canadian based) - Professor / Health, PFAS expert (Cambridge UK based) - Leading Senior Government PFAS specialist (Australian Qld based) - A/Professor / Head, Laboratory Haematology and Chair of a Hospital Transfusion Committee (Australian Vic based)
The selection of Macquarie University for this research was influenced by Macquarie University’s’ previous commissions on related PFAS research, with the NSW EPA, around Williamtown RAAF Base.
This research study is a randomized interventional study to compare a number of intervention groups donating blood or plasma and a control group with no intervention. It is anticipated that the study may identify a possible relationship between the interventions and reduced levels of PFAS after 16 months (baseline +12 month intervention period).
Macquarie University is providing the overall coordination of the study, clinical and academic expertise, statistical analysis and report and manuscript for publication in a peer-reviewed journal.
10 https://www.parliament.vic.gov.au/images/stories/committees/enrc/Fiskville_training_college/ENRRDC_58- 01_TIL_Text_WEB.pdf 11 goto.mq/pfas
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5. FRV Fire Station PFAS Soil, Water and Fruit & Vegetable Testing
FRV acknowledges its use of PFAS containing fire fighting foam prior to 2014. FRV also acknowledges its obligation to provide a safe workplace for its employees. Due to this, FRV is working to clarify the exposure pathways and levels of PFAS exposure its employees have. In 2018 MFB commissioned independent Environmental Consultants and Testing Laboratories to collect and analyse levels of PFAS in both the soil and the fruits or vegetables grown at MFB Fire Stations. As part of this work, as of May 2020, there have been various subsequent rounds of PFAS testing and site remediation work;
Round 1: January 2019: Independent PFAS testing of fruit or vegetables samples at 16 MFB Fire Stations that grew fruit or vegetables.
Round 2: July 2019: Independent PFAS testing of soil in the vegetable gardens or property boundaries of 8 of the 16 MFB Fire Stations tested earlier. The results indicated that at 4 MFB fire stations, the reported PFAS concentrations in soil samples exceeded the adopted criteria for residential land use, as per PFAS National Environmental Management Plan (NEMP, HEPA 2018) guidelines12.
Round 3: October 2019: The July 2019 PFAS soil testing results prompted MFB to invest in funding independent PFAS soil testing of all 47 MFB Fire Stations. MFB then commissioned independent environmental consultants to draft a MFB Fire Station Risk Prioritisation report that lists/ranks, in order, the MFB Fire Station preliminary measured PFAS levels.
Round 4: December 2019 – Feb 2020: The above previous rounds of testing informed further PFAS soil and/or water and/or biota testing on selected neighbouring properties around 6 MFB Fire Stations and other selected properties. These results and the MFB Fire Station Risk Prioritisation report was proactively provided to Victorian EPA. MFB is awaiting the specific direction regarding further remediation from the Victorian Environment Protection Authority.
12 https://www.epa.vic.gov.au/your-environment/land-and-groundwater/pfas-in-victoria/pfas-national- environmental-management-plan
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Further rounds: Feb – May 2020: PFAS soil and water testing at former MFB Fire Station at Templestowe Victoria PFAS soil and water testing at former MFB Fire Station at Rosanna Victoria Further soil testing and remediation work at Keilor Child Care Centre (next door to Keilor MFB Fire Station.)
6. FRV Fire Station ‘Dust Safe’ Initiative – Measuring PFAS, Asbestos, Diesel particulates at all FRV Fire Stations
FRV has commissioned Macquarie University, Department of Environmental Sciences to conduct a ‘Dust Safe’ initiative, which collects and analyses dust for PFAS, Asbestos and Diesel particulates at all FRV Fire Stations.
The FRV Fire Station ‘Dust Safe’ initiative is in response to frequent requests from operationalFRV fire fighters working at FRV Fire Stations to assist and clarify the level of PFAS exposure due to MFB’s previous use of PFAS containing fire fighting foam.
These FRV Fire Station Dust Safe results will also be correlated to the FRV PFAS soil testing results from the outside of Fire Station buildings.
7. FRV’s ‘PFAS Testing and Decontaminating process’ of FRV Appliances
Following the establishment of the safe PFAS thresholds, in 2016, MFB embarked on a process to test and decontaminate the MFB firefighting fleet. This process was developed with the assistance of MFB subject matter experts and external firms and was completed in 2019.
MFB arranged for the testing of its firefighting fleet, which identified that the majority of the fleet were heavily contaminated with PFAS, due to persistent residues from the previous foam concentrates. MFB then developed an effective 32 stage process to decontaminate its appliances of PFAS.
This truck decontamination process is overseen by two independent environmental consulting firms, in additional to being peer reviewed. Independent testing of completed appliances has shown remarkable results with 75% of the FRV fleet now having been decontaminated to below the established thresholds of 1000ppt for total PFAS and the remaining 25% to below 70ppt for total PFAS.
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Earlier in 2019, all MFB fire appliances were successfully cleaned and returned to operations. To our knowledge, FRV is the only firefighting authority in the world that has achieved this.
Furthermore, over 5,500 lengths of fire fighting hose (around 150 kilometres in length), have been successfully cleaned and returned back into commission for operational use.
Due to the verified success of this PFAS decontamination work, FRV has assisted other emergency service agencies, including the Department of Defence, to either advise or provide similar decontamination processes for their respective firefighting appliances.
8. FRV PFAS Threshold Limits
MFB formally endorsed drinking water guidelines specifying the acceptable level of the combined concentrations of PFOS and PFHxS at 70ppt (parts per trillion), plus PFOA at 70ppt at its VEMTC facility to ensure safe systems of work for VEMTC attendees.
This occurred after independent National Association of Testing Authorities (NATA) accredited testing confirmed the contamination results. Safe PFAS Threshold Exposure Limits were established for both firefighting water as well as firefighting training water. These thresholds were established after rigorous, peer reviewed, and independent analysis of human health risk assessments. These threshold limits were further validated by independent analysis from Dr Roger Klein (Cambridge, UK) and Nigel Holmes (Queensland Department of Environment & Heritage).
The process involved subject matter experts from the (United Firefighters Union Australia (UFUA), MFB, CFA, GHD environmental scientists, EPA and WorkSafe. All parties have endorsed the document.
9. Victorian Emergency Management Training Complex (VEMTC)
The Victorian Emergency Management Training Complex (VEMTC) is a 19 hectare, $109 million, world-class training facility operated by FRV. This facility provides training not only for FRV firefighters, but also for thousands of emergency services personnel from the Country Fire Authority, Victoria Police, Ambulance Victoria, Victorian Department of Environment, Land, Water and Planning and the State Emergency Service (SES). VEMTC also facilitates counter terrorism training for Australian Defence Force personnel. The facility incorporates state-of-the-art
Fire Rescue Victoria realistic emergency scenarios tailored to Melbourne's unique urban landscape, including laneways, rail tunnels, residential and high rise structures.
VEMTC is serviced by a reticulated ring main, supplied by a recycled potable water treatment plant. In the event of PFAS detection, this potable water treatment plant is isolated and the water supply reverts to the town’s main supply. Additionally there is a petrol chemical prop at this facility and it is the only area where foam training occurs. This is serviced by a separate water treatment plant where the water is not reused, but after treatment, diverted to trade waste. MFB’s PFAS mitigation work for VEMTC included researching and setting PFAS threshold limits in conjunction with Victorian EPA, the CFA and WorkSafe.
10. Suggested legislative / regulatory updates
FRV’s view is that national leadership is required for the communication of research findings and coordinating a combined policy response to PFAS issues. This should include the development of regulatory and legislative responses and the communication of these developments to potentially affected individuals and organisations.
FRV acknowledges there is no existing Victorian State Government or Federal legislation banning or restricting the use of PFAS-containing firefighting foam. However, to mitigate against the further contamination of sites, including those belonging to the Commonwealth, FRV has developed a policy governing the use of non-FRV approved foam concentrate in FRV appliances and at sites including Commonwealth and Major Hazard Facilities ( the ‘Operational Use of Firefighting Foam Policy’(See attached Schedule 1)). This policy was also formally endorsed by the Victorian Environmental Protection Authority (EPA), WorkSafe and the Country Fire Authority (CFA). FRV considers this measure essential for the protection of emergency responders, industry, community members and the environment.
Furthermore, MFB developed and endorsed the following MFB Fire Safety Guidelines; “GL-11 Foam-Water Fire Protection Systems and Foam Concentrate Storage Provisions” (See attached Schedule 3), and “GL-12 Considerations for Fire Water Run-Off at Dangerous Goods Sites” (See attached Schedule 4), that outline some of FRV’s expectations regarding foam and firewater run-off.
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11. Adequacy of health advice and testing of current and former defence and civilian personnel and members of the public exposed in and around Defence bases identified as potentially affected by contamination;
The response to PFAS requires consistent coordination of health advice and testing for individuals who may potentially be affected by PFAS. This would ensure that the impacts of PFAS are better identified in the Australian context.
Although FRV is not responsible for health advice and testing of current and former Defence and civilian personnel and members of the public exposed in and around Defence bases, it has taken a lead in the testing of appliances and equipment that is used in emergency response, including for Defence sites. This will ensure that FRV limits the exposure of PFAS-containing products from FRV equipment used on Commonwealth sites including Airbases.
FRV’s position on this is based on independent third party advice, in particular ‘The MFB Summary Risk Assessment report’, commissioned by MFB and authored by GHD (See Schedule 5).
12. 2018 PFAS National Environmental Management Plan
FRV supports the recent 2018 PFAS National Environmental Management Plan,13 that was designed to achieve a clear, effective coherent and nationally consistent approach to the environmental regulation of PFAS.
FRV recognises the important role of Australia’s health-based guidance on PFAS and the requirement ongoing research to better understand the human health effects. Since these chemicals remain in humans and the environment for many years, it is recommended that as a precaution, human exposure to PFAS be minimised.
This is consistent with FRV’s “As Low As Reasonably Practical” (ALARP) / precautionary principle in the development of policy and procedures, as being most appropriate.
13 https://www.epa.vic.gov.au/your-environment/land-and-groundwater/pfas-in-victoria/pfas-national- environmental-management-plan
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13. FRV operations at Victorian RAAF bases
MFB/FRV and the Department of Defence have had formal incident response arrangements for the delivery of emergency services to Defence bases including RAAF Airbases at Point Cook and Laverton. These arrangements in the past required MFB to use firefighting foams that contain Perfluorooctanesulfonic acid (PFOS).These foams were used during certain types of emergencies, such as military air craft accidents and under the direction of the RAAF Base Commander.
The use of these firefighting foams proved to be effective in the control of flammable liquid fires; however the constituents were neither known nor fully understood by MFB. FRV understands that RAAF was aware that firefighting foams containing PFOS were used at all Commonwealth facilities that require this type of firefighting operations.
When using this type of PFOS containing firefighting foam, its application requires significant quantities of foam concentrate delivered premixed with water and applied in a blanket form over the affected area. This resulted in PFAS being present in residual soils, water and other natural assets and built structures.
14. Defence and Air Services Australia Visit
FRV is an industry leader in a range of the measureable PFAS mitigation and decontamination work. Some of this work is world-leading and is leading Australia.
Due to MFB and FRV’s work, many other Australian Firefighting Agencies have approached FRV for PFAS mitigation advice and management.
On 30 May 2018, 7 Australian Defence Force and Australian Air Services representatives visited one of MFB’s PFAS decontamination sites to see first-hand some of the successful and measureable PFAS mitigation processes that MFB developed.
During this site visit, MFB outlined the below PFAS Mitigation work to the Australian Defence Force and Australian Air Services representatives;
MFB ‘Operational Use of Firefighting Foam Policy’ (Endorsed by the Victorian Environmental Protection Authority (Vic EPA), Victorian WorkSafe and the Victorian Country Fire Authority (CFA). (See attached Schedule 1.) MFB’s Appliance (Fire Truck) PFAS Decontamination processes (Independently verified by third parties.)
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MFB’s Victorian Emergency Management Training Complex (VEMTC) PFAS monitoring and mitigation work MFB’s setting of safe PFAS Threshold Exposure Limits, whereby MFB have formally endorsed drinking water guidelines specifying the acceptable level of the sum of PFOS and PFHxS. In addition to PFOA at 70ppt. MFB’s testing of PFAS levels of MFB operational firefighters and mechanical workshops staff. MFB’s / Macquarie University Firefighter PFAS Blood/Plasma Research Study.
Schedules
Schedule 1: MFB ‘Operational Use of Firefighting Foam Policy’
Schedule 2: 16/05/2000 notification from US EPA to various Australian Government Agencies
Schedule 3: MFB Fire Safety Guidelines; “GL-11 Foam-Water Fire Protection Systems and Foam Concentrate Storage Provisions”
Schedule 4: “GL-12 Considerations for Fire Water Run-Off at Dangerous Goods Sites”
Schedule 5: ‘The MFB Summary Risk Assessment report’, commissioned by MFB and authored by GHD