Per- and polyfluoroalkyl substances (PFAS) are a group of synthetic chemicals used in various industrial applications, including Aqueous Film-Forming Foam (AFFF) for firefighting. Due to their persistence in the environment and potential health risks, PFAS have been subject to increasing regulatory scrutiny.
Key Regulations and Restrictions
- Stockholm Convention and EU POPs Regulation: The Stockholm Convention, implemented in the EU through Regulation (EU) 2019/1021, restricts the use of PFAS in firefighting foams. Specifically, the regulation limits the concentration of perfluorooctanoic acid (PFOA) and its salts to 0.025 mg/kg and PFOA-related compounds to 1 mg/kg.
- Upcoming EU Restrictions: Germany has proposed further restrictions on undecafluorohexanoic acid (PFHxA), which the European Chemicals Agency (ECHA) has evaluated. The EU Member States have voted in favour of these restrictions, which are now under review by the European Parliament and Council.
- Waste Management Requirements: The Waste Management Acts 1996-2008 mandate that any facility involved in the recovery or disposal of waste must hold a License, Permit, or Certificate of Registration. This includes the proper management and disposal of waste fire extinguishers containing PFAS.
Recommendations
Given the stringent regulations and the environmental impact of PFAS, I recommend the following actions:
- Assess Current Inventory: Evaluate your current stock of AFFF fire extinguishers and identify those containing PFAS. Ensure compliance with the current limits and prepare for future restrictions. This aligns with the requirements outlined in Section 5.1 of I.S. 291:2015+A1:2022 regarding the suitability of portable fire extinguishers (PFEs).
- Transition to Alternatives: Consider transitioning to fluorine-free firefighting foams or other alternatives that comply with upcoming regulations. This proactive approach will help you avoid legal requirements and reduce environmental impact. Section 5.3 of I.S. 291:2015+A1:2022 guides the provision of PFEs, which should be considered when selecting alternatives.
- Proper Disposal and Documentation: Ensure that waste fire extinguishers are handled by authorised facilities. Obtain “End of Life” Certificates and maintain disposal records to comply with waste management regulations. This aligns with the record-keeping requirements outlined in Section 7.10 of I.S. 291:2015+A1:2022.
- Training and Awareness: Update your training programs to exclude using PFAS-containing foams. Educate your staff and clients about the new regulations and the importance of environmentally friendly alternatives. This aligns with the responsibilities outlined in Section 4.1 of I.S. 291:2015+A1:2022 regarding the responsibility of the person having control over fire safety provisions.
Conclusion
Navigating the regulatory landscape surrounding PFAS in firefighting foams is crucial for ensuring compliance and protecting the environment. By assessing current inventories, transitioning to safer alternatives, ensuring proper disposal, and updating training programs, we can collectively contribute to a safer and more sustainable future.
References
- I.S. 291:2015+A1:2022, Selection, commissioning, installation, inspection and maintenance of portable fire extinguishers and Amendment 1
- https://echa.europa.eu/-/echa-s-committees-eu-wide-pfas-ban-in-firefighting-foams-warranted
- https://www.epa.ie/publications/monitoring–assessment/waste/65203287-PFOA-EPA-Factsheet-Final.pdf
- https://www.irishstatutebook.ie/eli/2007/si/821
- https://echa.europa.eu/-/echa-s-risk-assessment-committee-backs-pfas-ban-in-firefighting-foams
- https://www.epa.ie/publications/monitoring–assessment/waste/AFFF-Booklet-Web.pdf
- https://assets.gov.ie/243917/993e3ac0-cd80-4706-9ba7-f108c4867ba5.pdf
- https://echa.europa.eu/view-article/-/journal_content/title/9109026-321
- https://www.epa.ie/publications/monitoring–assessment/waste/PFAS-in-fire-fighting-foam-report-web-version.pdf
- https://www.irishstatutebook.ie/eli/2023/si/471/made/en/print
- https://echa.europa.eu/view-article/-/journal_content/title/9109026-134
- https://www.epa.ie/publications/monitoring–assessment/waste/AFFF-Posters-Web.pdf
- https://www.gov.ie/en/service/bdb1d-waste-management-facility-permits/
- https://echa.europa.eu/-/proposal-to-ban-forever-chemicals-in-firefighting-foams-throughout-the-eu
- https://www.epa.ie/publications/monitoring–assessment/waste/Chemical-Information-for-Users-of-Foam-Fire-Extinguishers—PFOA-information-leaflet-2.pdf
- https://www.epa.ie/publications/licensing–permitting/waste/application-for-a-certificate-of-registration-as-set-out-in-the-waste-management-facility-permit-and-registration-regulations-2007-as-amended.php
- https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas
- https://www.epa.ie/publications/monitoring–assessment/waste/Information-for-Suppliers-of-Foam-Fire-Extinguishers—PFOA-information-leaflet-1.pdf
- https://www.gov.ie/en/service/f94dd-waste-facility-permit/
