Compliance advice issued for PFOA in Class B firefighting foams

The UK POPs Regulation bans the production, placing on the market and use of substances, mixtures and articles containing PFOA, its salts and PFOA-related compounds. PFOA, its salts and PFOA-related compounds remain in the environment for very long periods of time, are toxic and gradually build up to harmful levels in living organisms.

They have previously been used as active ingredients in Class B firefighting foams, and particularly so within aqueous film forming foams, in the main due to their surfactant properties. They may also be present in foams as a contaminant.

There is currently an exemption in place for the use of PFOA, its salts and PFOA-related compounds in firefighting foams for Class B fires already installed in systems, including both mobile and fixed systems. This exemption remains in place until 4 July 2025, subject to certain conditions being met.

Practitioners need to have confidence that they’re in compliance with the law. To ascertain whether or not foam contains PFOA, its salts and/or PFOA-related compounds, practitioners can check the safety data sheet for the foam, contact the supplier or manufacturer of the foam or otherwise have the foam analysed by a registered and suitable laboratory.

Legal obligation

If there’s an intention to use – or otherwise maintain a stockpile of – Class B foam already installed in systems which contain (or may contain) PFOA, its salts and/or PFOA-related compounds, there’s a legal obligation to meet the following conditions:

*Holders of stockpiles of greater than 50 kg must notify the Environment Agency by completing a stockpile notification form (see link below) and forward this to chemicalrestrictions@environment-agency.gov.uk

*The Environment Agency must be notified as soon as possible if a POPs stockpile is being held

*The firefighting foam must not be used for training purposes

*The firefighting foam must not be used for testing unless all releases are contained.

*As of Sunday 1 January 2023, the use of firefighting foam containing PFOA will only be allowed at sites where all releases can be contained

The POPs stockpile notification form can be found online at www.gov.uk/government/publications/persistent-organic-pollutants-notifying-pops-stockpiles

Definition of substances

Supporting information has been provided on the definition of substances referred to as PFOA, its salts and PFOA-related compounds and the concentration limits for unintentional trace contamination.

PFOA, its salts and PFOA-related compounds as set out by the UK POPs Regulation means the following:

(i) Perfluorooctanoic acid (including any of its branched isomers)

(ii) its salts

(iii) PFOA-related compounds, which are any substances that degrade to PFOA, including any substances (among them salts and polymers) having a linear or branched perfluoroheptyl group with the moiety (C7F15)C as one of the structural elements

*Further information on the use, storage and disposal of POPs (including PFOA) can be found online at www.gov.uk by searching for “Persistent organic pollutants”