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Update to MFB Submission to the PFAS Sub- Committee of the Joint Standing Committee on Foreign Affairs, Defence and Trades

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Update to MFB Submission to the PFAS Sub- Committee of the Joint Standing Committee on Foreign Affairs, Defence and Trades 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. Fire Rescue Victoria 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 Fire Rescue Victoria 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 Fire Rescue Victoria (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
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