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Fluorine-Free Firefighting Foams (3F) Viable Alternatives to Fluorinated Aqueous Film-Forming Foams (Afff)

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Fluorine-Free Firefighting Foams (3F) Viable Alternatives to Fluorinated Aqueous Film-Forming Foams (Afff) FLUORINE-FREE FIREFIGHTING FOAMS (3F) VIABLE ALTERNATIVES TO FLUORINATED AQUEOUS FILM-FORMING FOAMS (AFFF) Independent Expert Panel Convened by IPEN Stockholm Convention POPRC-14 Rome September 2018 FLUORINE-FREE FIREFIGHTING FOAMS (3F) – VIABLE ALTERNATIVES TO FLUORINATED AQUEOUS FILM-FORMING FOAMS (AFFF) Allcorn, M. a, Bluteau, T. b, Corfield, J. c, Day, G. d, Cornelsen, M. e, Holmes, N.J.C. f, Klein, R.A. g, McDowall, J.G. h, Olsen, K.T. i, Ramsden, N. j, Ross, I. k, Schaefer, T.H. l, Weber, R. m, Whitehead, K. n. a Alert Disaster Control, Loyang Crescent, Singapore b Leia Laboratories, France c Brisbane Airport Authority, QLD Australia d London Heathrow Airport, United Kingdom e Cornelsen Umwelttechnologie GmbH, Essen, Germany f Department of Environment and Science, Queensland Government, Australia g Cambridge, United Kingdom; Christian Regenhard Center for Emergency Response Studies, John Jay College of Criminal Justice, City University New York (CUNY), NY USA h 3FFF Ltd, Corby, Northants., United Kingdom i Copenhagen Airports, Denmark j LASTFIRE and ENRG Consultants, Monks Risborough, United Kingdom k Arcadis, Manchester, United Kingdom l Penrith, NSW Australia m POPs Environmental Consulting, Schwäbisch Gmünd, Stuttgart, Germany n Unity Fire & Safety, Oman White Paper prepared for the IPEN by members of the IPEN F3 Panel and associates, POPRC-14, Rome 17-21 September 2018. © 2018 IPEN and the authors listed as F3 Panel Members Cite this publication as: IPEN 2018/POPRC-14, White paper, Fluorine-free firefighting foams (3F) – Viable alternatives to fluorinated aqueous film-form- ing foams (AFFF). Corresponding author: R. A. Klein <[email protected]> IPEN is a network of non-governmental organizations working in more than 100 countries to reduce and eliminate the harm to human health and the environment from toxic chemicals. www.ipen.org ii CONTENTS Introduction ..................................................................4 Appendix I Statement of the Problem .......................46 The F3 Panel ..................................................................5 Appendix II Some General Points on PFAS ...............49 Executive Summaries Appendix III Graeme Day English (EN) ..................................................................7 Transitioning to F3 at London Heathrow Airport .................................... 55 French (FR français) ......................................................9 Appendix IV Nigel Holmes Spanish (ES español) ....................................................11 PFAS – The Regulator’s Chinese (ZH 中文维基百科) .......................................... 13 Perspective ................................................56 Russian (RU Обзор) ..................................................... 14 Appendix V Roland Weber How to Prevent the Use of Toxic Arabic (AR ) ............................................... 16 -Chemicals Per- and Polyfluorinated Alkyl ملخص يذيفنت تنفيذيصخلم Stakeholder End-Users ................................................ 18 ated Substances (PFASs) 1. Firefighting Foams ................................................... 19 in Firefighting Foams ..............................59 1.1. Types of Firefighting Foams – Class A and Class B 19 Appendix VI Niall Ramsden 1.2. A Brief History of the Development of Fluorine-Free LASTFIRE and foam performance ... 61 Class B Foams ............................................................. 19 Appendix VII Ted H. Schaefer 1.3. Approvals & Certifications - Fluorine-Free Class B A Brief History of the Development Foams ...........................................................................20 of F3 Foams .............................................64 1.4. Myth Busting, truths, untruths and Marketing Hype 22 Appendix VIII Kim T. Olsen Transitioning to F3 Copenhagen 2. Acute Aquatic Toxicity versus Biochemical Oxygen Airport (CPH) ...........................................66 Demand (BOD) & Chemical Oxygen Demand (COD) for Firefighting Foams ...........................................28 Appendix IX Nigel Holmes AFFF versus F3: performance 3. Exposure, Chronic Toxicity and Environmental and incidents ............................................67 Persistence ............................................................ 31 3.1. The Precautionary Principle ..................................... 31 Appendix X Thierry Bluteau Reducing BOD/COD – Solvent-Free 4. Contaminated Runoff, Waste Disposal, Foams ........................................................69 Remediation ..........................................................33 4.1. Examples of Large Volume PFAS- Appendix XI Gary McDowall Contamination Impacts .............................................34 Hand-Held and Portable 4.1.1. Australia ..............................................................34 Extinguishers ............................................70 4.1.2. United Kingdom ................................................35 Appendix XII Kevan Whitehead 4.1.3. Germany .............................................................35 End User Oil and Gas Industry 4.1.4. United States of America ..................................36 Firefighting Observations ....................... 71 4.1.5. Hand-held and portable extinguishers ...........36 4.1.6. Disposal of firefighting foam wastes ............... 37 Endnotes .....................................................................73 4.1.7. Remediation and clean-up................................ 37 5. Socio-economic Costs...............................................38 5.1. Transitioning to best practice ....................................39 5.2. The Queensland Foam Policy transition experience ..................................................39 6. Examples of Transition from AFFF to F3 ................................................... 42 6.1. Petrochemical Industry ..............................................42 6.2. Aviation Rescue and Firefighting (ARFF) ..............44 7. Concluding Remarks ................................................45 Fluorine-free Firefighting Foams (3F) (September 2018) iii INTRODUCTION IPEN respectfully presents this paper, Fluorine-Free Fire- U.S. Agency for Toxic Substances and Disease Registry’s fighting Foams—Viable Alternatives to Fluorinated Aque- Toxicological Profile concluded that health advisory levels ous Film-Forming Foams (AFFF), prepared by eminent, for PFOA and other evaluated PFAS far exceed health pro- independent experts for consideration by the Stockholm tective standards based on sensitive health endpoints such Convention Persistent Organic Pollutants Review Commit- as immune effects. tee (POPRC), observers, and the public. We believe that it offers a fresh perspective from experts in the field who have Based on the evidence presented in this paper concerning direct experience and knowledge concerning the efficacy the availability, effectiveness, and certifications of fluorine- of fluorine-free firefighting foams as safer substitutes for free firefighting foams, we affirm that no exemptions for AFFF. The paper concludes: “The continued use of PFAS continued production and use of PFOA and its precursors (per- and polyfluorinated substances) foams is not only un- or PFOS in AFFF should be recommended and no exemp- necessary but would continue to add to the legacy and on- tion should permit continued use of existing AFFF stock- going contamination that is responsible for the substantial, piles containing PFAS substances. We further caution that widespread and growing socio-economic and environmental replacement of other per-and polyfluorinated substances in costs being experienced globally.” We hope that the evidence AFFF including short-chain PFAS, would be regrettable presented in the paper will contribute toward decisions that substitutions that perpetuate harm to the environment and will prevent further harm to the global environment and human health. Precaution is embedded in the Stockholm human health caused by the dispersive contamination as- Convention and protective action is a moral imperative for sociated with continued production and use of fluorinated implementing treaty objectives. aqueous film-forming foams (AFFF) used in firefighting. Pamela Miller The POPRC has made crucial determinations about PFOA, IPEN Co-Chair including the conclusion in the Risk Profile (UNEP/POPS/ POPRC.12/11/Add.2) that, “based on the persistence, bioac- September 9, 2018 cumulation, toxicity in mammals including humans and widespread occurrence in environmental compartments, it is concluded that PFOA, its isomers, salts and related com- pounds that degrade to PFOA, as a result of their long-range environmental transport, are likely to lead to significant adverse human health and environmental effects such that global action is warranted.” In assessing the adverse human health effects of PFOA in the Risk Profile (UNEP/POPS/ POPRC.12/11/Add.2), the Committee notes that the Inter- national Agency for Research on Cancer classifies PFOA as a Class 2B carcinogen with particular regard to testicu- lar and kidney cancers. The Risk Profile also summarizes epidemiological evidence linking PFOA exposure with high cholesterol, inflammatory diseases, ulcerative colitis, thy- roid disease, immune effects, pregnancy-induced hyperten- sion, endocrine disruption and impaired neuro- as well as reproductive development. New insights about the adverse health effects of PFAS chemicals at exquisitely low exposure levels, including PFOA and PFHxS, are coming to light in the peer-reviewed
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