The environmental concerns and related liability associated with per- and polyfluoroalkyl substance (PFAS) are well known.
One of the potential primary sources of PFAS at airport operations, terminals, fire training facilities, chemical companies, refineries, fuel tank farms, chemical warehouses, etc., is Aqueous Film Forming Foam (AFFF or A triple F). Due to its effectiveness in suppressing fuel fires, AFFF has been required at airports that provide commercial passenger service since 1988.
There has been pressure on lawmakers to address all sources of PFAS, including AFFF.
Federal Aviation Administration Firefighting Foam Transition Plan
On May 8, 2023, the Federal Aviation Administration (FAA) issued their “Aircraft Firefighting Foam Transition Plan.” This plan, required as part of a December 2022 Congressional directive, provides guidance to transition from AFFF to Military Specification Fluorine Free Foam, or MILSPEC FFF.
Currently, the FAA has not mandated the use of MILSPEC FFF at commercial airports. That being said, states, local governments, and/or airport authorities may require the transition. Additionally, airports may decide to transition to FFF to avoid the growing environmental liability associated with AFFF discharges and PFAS residuals.
Beyond new foam availability, the transition to MILSPEC FFF will be a significant undertaking. Among the environmental obligations of the transition will be disposal of existing AFFF and decontamination of existing equipment.
If you are seeking to transition from AFFF to MILSPEC FFF, Dragun can help. For more information, contact Matthew Schroeder, M.S., P.E. at 248-932-0228, Ext. 117.
This blog was drafted by Alan Hahn. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for 45 years. He has written hundreds of blogs and articles. His published work includes Michigan Lawyers Weekly, Detroiter, Michigan Forward, GreenStone Partners, Manure Manager Magazine, Progressive Dairy, and HazMat Magazine.
This blog was reviewed and edited by Matthew Schroeder, M.S., P.E. Matt is a senior environmental engineer at Dragun Corporation. Matt has 30 years of experience with soil and groundwater remediation, vapor intrusion, and more recently with PFAS. Specific to PFAS, Matt has completed the ITRC PFAS Training, is a member of the Michigan PFAS Action Response Team, Treatment Technology Roundtable, and the Michigan Manufacturers Association PFAS Work Group, and he has participated in the PFAS Experts Symposium. Matt is a frequent speaker, author, and expert witness. See Matt’s bio.