AFFF Firefighting Foam: Compliance, Alternatives & Next Steps

AFFF firefighting foam, known for its effectiveness against Class B liquid fires, is being phased out across the UK due to its harmful PFAS content, including PFOA. These “forever chemicals” are persistent in the environment and pose significant health risks, making compliance with new regulations crucial for businesses. The UK’s 2025 ban on AFFF foam means that responsible persons and business owners must understand and prepare for the transition.

This guide will outline the legal requirements, risks associated with PFOA in firefighting foams, and practical steps for adopting safer, fluorine-free alternatives to maintain compliance and protect the environment.

Understanding AFFF Firefighting Foam and PFAS Regulations

AFFF (Aqueous Film Forming Foam) firefighting foam has long been a go-to for businesses needing effective fire suppression against Class B fires, which involve flammable liquids like gasoline, oil, and certain chemicals. Its unique formulation allows it to form a thin film over burning liquids, cutting off the fire’s oxygen supply and cooling the flames.

However, AFFF firefighting foam contains PFAS (Per- and polyfluoroalkyl substances), including PFOA, which are often called “forever chemicals” due to their persistence in the environment and their bioaccumulative nature.

Over time, these chemicals build up in living organisms, such as fish, wildlife, and even humans, where they accumulate in tissues and organs. This bioaccumulation can lead to severe health issues, including endocrine disruption, immune system impairment, and increased risk of certain cancers. In the environment, PFAS contamination impacts entire ecosystems by persisting in soil and water, potentially affecting groundwater and drinking water sources, which then cycles back into the food chain.

Many businesses, especially those handling flammable materials, rely on Class B fire extinguishers for safety. Examples include:

Automotive and Car Dealerships: These facilities typically store and handle flammable fuels, oils, and lubricants, necessitating Class B extinguishers.
Manufacturing and Industrial Sites: Industrial operations often involve processes with solvents, lubricants, and chemicals that carry a high fire risk, requiring AFFF or other Class B solutions.
Warehouses with Chemical Storage: Warehouses storing or distributing flammable liquids like alcohol-based products, cleaning agents, or paints rely on Class B fire protection to mitigate fire risks.
Airports and Aviation Hangars: With fuel storage and refueling zones, airports are particularly susceptible to liquid fires, making Class B suppression methods essential.
Laboratories: Labs using flammable solvents or chemicals require effective Class B suppression to manage potential risks and maintain safety.

Given the regulatory shift, businesses using AFFF firefighting foam must now prepare to transition to alternatives that comply with PFAS regulations, which come into full effect in July 2025.

Current Regulatory Landscape on PFAS in the UK and Europe

In response to the growing concerns about PFAS, the UK and EU have introduced stringent regulations on AFFF firefighting foam use:

2011 PFOS Ban: The use of PFOS, an early PFAS used in firefighting foams, was banned in the UK and EU in 2011 due to environmental and health risks.
PFOA Restrictions and Upcoming Ban: Since 2020, restrictions on PFOA in firefighting foams have limited its use to scenarios where foam releases can be contained. By 2025, the UK and EU will fully prohibit AFFF firefighting foam containing PFOA, requiring businesses to manage or replace their foam supplies.
Limitations on Training and Testing: Businesses are prohibited from using PFOA-containing AFFF for training, and any testing must ensure releases are fully contained to avoid environmental contamination.
Future PFAS Regulations: The EU is considering further restrictions on all non-essential uses of PFAS, potentially affecting any remaining firefighting foams that contain these chemicals and pushing the industry toward fluorine-free solutions.

For businesses, compliance with these regulations is critical, not only for legal adherence but also for environmental and public health safety.

The Risks of AFFF and PFOA for Businesses and the Environment

The phase-out of AFFF firefighting foams containing PFAS, including PFOA, represents an important step in environmental protection and public health. However, businesses using these foams must be aware of both the risks associated with PFAS and the compliance requirements they face.

Why PFAS in Firefighting Foam Are Harmful

AFFF firefighting foam, containing PFAS chemicals like PFOA, presents considerable environmental and health risks. Known as “forever chemicals,” PFAS break down very slowly, if at all, in the environment, leading to persistent contamination. These chemicals, including PFOA, were historically used in products like non-stick frying pans until phased out in 2013 due to health concerns.

In firefighting foams, PFAS can easily contaminate water sources such as rivers, lakes, and groundwater, impacting entire ecosystems and posing serious risks to human health. Once released, PFAS accumulate in living organisms—including fish, wildlife, and humans—where they build up in tissues over time. This bioaccumulation has been linked to a range of health issues, including immune system damage, endocrine disruption, and increased cancer risks. For ecosystems, PFAS contamination disrupts food chains and endangers biodiversity, highlighting the urgent need for safer alternatives in firefighting equipment.

Legal and Compliance Implications for Businesses

With the upcoming phase-out of AFFF firefighting foam containing PFOA by July 2025, businesses in the UK face critical legal obligations. Existing regulations already restrict the use of PFOA-based foams in training scenarios, allowing testing only if releases are fully contained.

As the 2025 deadline approaches, businesses using or storing AFFF foam must assess their firefighting equipment and prepare to transition to compliant, fluorine-free alternatives. Failing to meet these requirements could result in substantial fines, legal ramifications, and reputational harm, especially for companies in high-risk industries. Taking proactive steps to replace outdated foams not only shields businesses from legal consequences but also demonstrates a commitment to environmental stewardship and workplace safety.

Steps You Need to Take to Transition Away from AFFF Foam

To ensure compliance and safety, businesses need to start preparing for the transition away from AFFF firefighting foam. This involves conducting a detailed audit of current fire suppression systems and selecting suitable fluorine-free alternatives. Below are the key steps to take.

Conducting an Audit of Existing Fire Suppression Systems

Conducting a thorough audit of your existing fire suppression systems is the first step in the transition. This process will help identify any current stocks of AFFF foam and ensure all relevant records are up to date. Key actions include:

Checking Safety Data Sheets (SDS): Review the safety data sheets provided by foam manufacturers to determine if your current foam contains PFAS chemicals like PFOA.
Consulting with Manufacturers: Reach out to foam manufacturers or suppliers for confirmation on PFAS content, as not all safety data sheets explicitly list these chemicals.
Engaging Certified Professionals: Consider hiring certified fire safety professionals to conduct a comprehensive assessment of your fire suppression systems. These experts can identify PFAS-containing foams and advise on necessary adjustments.
Documenting All AFFF Stocks: Accurate documentation is essential, especially if your business holds over 50 kg of AFFF foam. This threshold requires notification to the Environment Agency and may be subject to additional storage and disposal requirements.

Conducting a fire foam audit ensures you’re aware of your current equipment, enabling you to make informed decisions about transitioning to safer, compliant alternatives.

Choosing Fluorine-Free Foam Alternatives

As the 2025 phase-out deadline approaches, it’s crucial for businesses to select effective and compliant firefighting foams that are free from harmful PFAS chemicals. Fluorine-free foams (F3) are an increasingly popular and sustainable choice. Here’s what you need to know about transitioning to these alternatives:

Understanding F3 Foam Properties: Unlike AFFF foam, F3 alternatives are free from harmful PFAS and can be safely used without the long-term environmental impact associated with PFOA. However, businesses must account for slight differences in viscosity and application rates when switching to F3 foams.
Compatibility with Existing Systems: Some existing fire suppression systems designed for AFFF foam may need adjustments for compatibility with F3. This might include modifications to ensure effective coverage and application rates tailored to the specific fire hazards present.
Engaging Fire Safety Professionals: To ensure smooth integration of F3 foam, it’s advisable to consult with fire safety professionals who can guide you through the transition. These experts can recommend the right F3 products and confirm that your system remains effective and compliant.

Choosing fluorine-free fire foam aligns with regulatory requirements and demonstrates a commitment to sustainability. By making this proactive change, businesses can enhance both their environmental responsibility and their readiness for the future.

Ensuring Compliance with Installation, Disposal, and Usage Requirements

To fully comply with regulations on firefighting foam, businesses must address not only the installation of new, compliant systems but also the safe disposal of existing AFFF foam stocks. Additionally, consistent staff training and regular compliance checks are essential to maintain operational safety and regulatory adherence.

Safe Disposal of Existing AFFF Foam Stocks

Proper disposal of AFFF firefighting foam stocks is a critical step in adhering to environmental regulations, especially given the persistence of PFAS chemicals in the environment. To ensure safe and compliant disposal:

Work with Certified Waste Disposal Contractors: Only certified contractors should handle AFFF foam disposal, as they have the expertise and authorisation to manage PFAS-containing materials in line with environmental standards.
Notify Relevant Authorities for Large Stocks: If your business holds over 50 kg of AFFF foam, you are legally required to notify the Environment Agency. This step is essential for regulatory compliance and ensures that stock levels are properly tracked.
Prevent Accidental Environmental Release: During disposal, ensure that no AFFF foam is accidentally released into the environment. Uncontained release can lead to severe environmental contamination and may result in legal consequences.

Following these steps for the safe disposal of AFFF helps protect both the environment and your business from the risks associated with PFAS waste mismanagement.

Training and Compliance Checks

Transitioning to fluorine-free firefighting foams also requires updated training and regular compliance checks. This helps ensure that all firefighting systems remain effective and compliant:

Train Staff on New Fluorine-Free Systems: Staff should be educated on the specific properties and handling procedures of fluorine-free foams. Training sessions should cover how to operate, store, and safely deploy these foams in fire emergencies.
Conduct Regular Compliance Checks and Testing: Regular testing and inspections are essential to confirm that all firefighting equipment remains in optimal condition. Schedule periodic compliance checks to verify that your systems meet the latest fire safety standards and regulatory guidelines.
Perform Fire Safety Maintenance Inspections: Routine maintenance should include inspecting extinguishers, verifying storage conditions, and updating training materials. Ensuring that all staff are familiar with emergency protocols reduces response times and enhances workplace safety.

By implementing a comprehensive approach that includes safe disposal, thorough training, and ongoing compliance checks, businesses can fully meet fire foam regulations and foster a safer environment for all.

Future Outlook on Firefighting Foam Regulations and Industry Trends

With the phase-out of AFFF and similar PFAS-based firefighting foams, the fire safety industry is undergoing a significant shift towards sustainable, eco-friendly suppression methods. This move is not only driven by impending legal requirements but also reflects a broader commitment to reducing environmental impact.

The Move Toward Eco-Friendly Fire Suppression

The fire safety industry is actively moving toward fluorine-free (F3) foams, designed to provide effective fire suppression for Class B fires without the environmental hazards linked to PFAS chemicals. These F3 foams meet the rising demand for fire suppression solutions that avoid persistent contaminants, often called “forever chemicals“, which can linger in ecosystems and water supplies.

Transitioning to F3 foams also aligns with growing corporate and public expectations around sustainability. Businesses adopting these safer alternatives demonstrate a proactive approach to environmental stewardship and regulatory foresight. Industries with high fire risk, such as manufacturing, transportation, and petrochemical facilities, are expected to be early adopters of these F3 systems, helping to set new standards for environmental responsibility in fire safety.

Staying Updated with Evolving Fire Foam Regulations

As UK regulations tighten around firefighting foams containing PFAS, businesses need to stay updated on regulatory changes and evolving compliance standards. Engaging with industry bodies, like the Fire Industry Association (FIA), can help businesses understand the latest standards and maintain compliance through timely updates on safer products, best practices, and legal requirements.

Spire offers support to businesses across the Midlands, London and Home Countiess who are facing these changes by providing expert guidance on compliant fire suppression solutions. Through tailored consultations, Spire ensures that companies are equipped with up-to-date fire safety systems that meet both legal and environmental standards, helping them navigate these regulatory shifts effectively.

Conclusion

The impending phase-out of AFFF foam requires businesses to take proactive steps to ensure full compliance with evolving fire safety regulations. Transitioning to eco-friendly fire suppression solutions is essential for legal adherence and aligns with broader environmental goals. Spire is committed to supporting companies at every transition stage—from auditing current systems to implementing compliant, safer alternatives that uphold fire safety standards and sustainability.

Contact Spire today for professional guidance in managing your fire safety systems and ensuring compliance with the latest regulations.