CRICOS Provider No. 00300K (NT/VIC) I 03286A (NSW) | RTO Provider No.

0373

PFAS and Fluorine-Free Firefighting Foams:

Performance vs Environment and Health
Bogdan Dlugogorski
Charles Darwin University
Recognition of Traditional owners
and Indigenous cultures
Charles Darwin University acknowledges the traditional
custodians of the land on which we’re meeting and pays
respect to Elders both past and present and extends that
respect to all Aboriginal and Torres Strait Islander people.

2
Outline
• PEFORMANCE: What is meant by performance of firefighting foams? How is
it measured and how is it used in equipment design and procurement?
• ENVIRONMENT: What are the issues with legacy PFOS, C8 and C8/C6
fluorotelomer-based foams? What type of foams will matter in 2020s? How
are these foams called and why?
• PERFORMANCE versus ENVIRONMENT and HEALTH: How do foam properties
stack against each other for two groups of modern foams: fluorine-free
foams and high-purity C6 fluorotelomer foams? Do we have enough data to
make a fair comparison? What measurements are we missing? The
precautionary principle.

3
Performance
Listed foams satisfy the specifications of the performance-based standard tests
• MIL-PRF-24385F(SH), Fire Extinguishing Agent, Aqueous Film-Forming Foam
(AFFF) Liquid Concentrate, for Fresh and Sea Water, US Naval Sea Systems
Command, 7 May 2019 (with Amendment 3); aka MilSpec
• UL 162, Standard for Safety: Foam Equipment and Liquid Concentrates, 8th
Edition, Underwriters Laboratory, 2018
• ICAO, Airport Services Manual, Part 1, Rescue and Fire Fighting, Chapter 8:
Extinguishing Agent Characteristics, pp. 43-53, International Civil Aviation
Organization, 4th Edition, 2014
• EN 1568-3, Fire Extinguishing Media, Part 3: Specification for Low Expansion
Foam Concentrates for Surface Application to Water-Immiscible Liquids,
European Standard, March 2018 (approved by European Committee for
Standardization on 8 October 2017)
4
Performance
While we focus today on these four standard tests, as they are most commonly
used in industry and defence, there are many others
• There is a companion standard to EN 1568-3, EN 1568-4 - Fire Extinguishing
Media, Part 4: Specification for Low Expansion Foam Concentrates for Surface
Application to Water-Miscible Liquids
• LASTFIRE – Large-Scale Atmospheric Tank Fire
• IMO – International Maritime Organization
• Each national department of defence has its own standard, e.g., DEF(AUST)
5706—Foam, Liquid, Fire Extinguishing, Aqueous Film Forming Foam; this
standard is used for procurement of foams by Australian Defence
• National Standards, e.g., the Chinese, GB 15308-2006, Foam Extinguishing
Agent
• ISO 7203-1: 2019 Fire Extinguishing Media-Foam Concentrates 5
 Performance
Why do we care about the performance of firefighting foams and why do we continuously improve them? Because foams that do
not perform effectively in fire situation expose people and infrastructure to unacceptable risks.
• Forrestal was equipped with protein foams, as fluorine
foams were undergoing testing and development at that
time.

• The test performed in 1967 indicated that fluorine foams

outperformed the protein foams in the ratio of 3:1.

• If the better foams had been implemented on Forrestal,

they could have mitigated the jet fuel fire on the flight
deck.

• Testing in 1968 confirmed compatibility of fluorine foams

with sea water and benefits of their deployment on the US
Navy ships.

• Forrestal tragedy let to rapid development of MilSpec and

performance improvements to fluorine foams.

Tatem et al., https://vdocuments.site/mil-f-24385f.html (accessed 27 Oct

2019) 6
https://navylive.dodlive.mil/2012/07/30/uss-forrestal-remembered-lessons-from-tragedy/ (accessed 27 Oct 2019)
Performance
Distinction needs to be made between standards that gauge foam performance and
those used to design equipment based the performance criteria.
• Performance standards (such as MilSpec, UL 162, ICAO and EN 1568-3) test, among
others, the time to extinguishment for specified foam-solution applications rate and
fire size; e.g., MilSpec requires (among others) the extinguishment of
o 28 ft2 (2.80 m2) fire
o of unleaded gasoline, with a preburn period of 10 s
o in 30 s
o by applying 2 gal/min (7.57 L/min)
hence the application rate density is 7.57 L/min divided by 2.60 m2 = 2.9 L/(m2 min)
• Design standards apply the application rate of foam-solution determined by
performance standards to design fire suppression hardware, multiplying it by
asafety factor of between 2.5 and 3, prior to its application in the development of a
system. 7
Performance
• The most important design standards are NFPA (National Fire Protection
Association) standards, e.g.,
o NFPA 11, Standard for Low-, Medium- and High-Expansion Foam, National Fire
Protection Association, 2016
o NFPA 403, Standard for Aircraft Rescue and Firefighting Services at Airports,
National Fire Protection Association, 2018
• Performance standards may be also combined with design standards, in one
document, as is the case of ICAO, Airport Services Manual, Part 1, Rescue and Fire
Fighting
In the reminder of the lecture today, for brevity, we will speak about three of the
oft-used performance standards, MilSpec, UL 162 and ICAO. If one buys a foam
concentrate, it is most likely that he/she will need to specify it according to one of
these standards (and EN 1568-3).
Let’s see how one of these standards work in practice: 8
• Foam concentrates are sold as 1 %, 3 % and 6 %. For example, 1 % concentrate, requires the user to dilute one part of the concentrate
with 99 parts of water, before aerating the foam solution to generate foam.
• Fire size = square pan 4.65 m2, fuel = commercial heptane, application rate density = 2.44 L/(min m2)
• Test segments: (i) ignition, (ii) preburn = 1 min, (iii) foam application time = 5 min, (iv) form drainage = 15 min prior to (v) two torch tests,
followed by attempts to (vi) reignite the fire to determine its burnback performance (fire may grow back but no more than 23 % of pan
size in 5 min)
9
• If the foam passes this test, the minimum design rate density is specified as 6.52 L/(min m2); i.e., the safety factor is 2.7.
Performance
Pan shape and Application Extinguish= Foam
Test Standard Fuel Preburn Drainage Burnback
size rate density ment application
m2 L/(min m2) s s s s s

Unleaded
MilSpec Circular, 2.6 2.91 10 30 90 60 ≥ 360, 25 %
gasoline
Commercial
UL 162 F3 Square, 4.65 2.46 60 300 300 900 ≥ 300, 23 %
heptane
Commercial
UL 162 AFFF Square, 4.65 1.64 60 180 180 540 ≥ 300, 23 %
heptane
ICAO Level B Circular, 4.5 Kerosene 2.5 60 60 120 120 ≥ 300, 25 %

ICAO Level C Circular, 7.3 Kerosene 1.56 60 60 120 120 ≥ 300, 25 %

10
Performance
Changes to fire performance requirements led to stricter performance criteria. For example, for the MilSpec, the figure below
illustrates the reduction of the maximum allowable extinguishment time, with new revisions of the standard.

• Because of the shortened maximum allowable

extinguishment time and constant flow rate,
similar decline has occurred in the application
density from 4.1 L/m2 in 1969 to 2.2 L/m2 in 1977
and to the current limit o 1.48 L/m2.

• Likewise, specifications were tightened on faster

fire knockdown.

• Finally, 25 % burnback time increased from 240 s

in 1969 to 360 s, at present.

Tatem et al., https://vdocuments.site/mil-f-24385f.html

(accessed on 27 Oct 2019)

11
 Let us now see the application of the safety factor derived from UL 162
• Demonstration test of a simulated fire of a small storage vessel, 12.8 m in diameter (129 m2 in area)
• The minimum safety factor must be 2.7; i.e., 6.52 L/(min m2).
• The design application is 10 L/(min m2), translating into a safety factor of 4.1.

• It would have been interesting to see the extinction of this fire at the UL 162 tested application rate density; i.e., at the 2.44 L/(min m2).
• That is, does this fluorine-free foam (F3) scale linearly, as legacy PFAS foams do? Would it extinguish the fire in less than 5 min if applied 12
at 2.44 L/(min m2)? Is there a problem with scaling in the performance of F3?
Performance
Types of firefighting foams
• Historically foams comprise 5 classes: (i) protein (P, as used on Forrestal in 1967),
(ii) fluoroprotein (FP), (iii) film forming fluoroprotein (FFFP), (iv) aqueous film
forming foams (AFFF) and (v) synthetic, also called as fluorine-free foams (F3).
• Protein, fluoroprotein and film forming fluoroprotein contain hydrolysed protein
derived from hooves and feathers. They decompose when in storage and about
25 % of the stored volume needs to be replaced yearly. FP and FFFP also contain
fluorosurfactants.
• While still available on the market, protein, fluoroprotein and film forming
fluoroprotein are used rather infrequently. In Australia, it seems that only one fire
service still uses FFFP, but has plans to replace it with the fluorine-free foams (F3).
• As there is no point to beat a dead snake, we will concentrate only on (new) AFFF
and F3 formulations.
13
Performance
What does film forming mean?
• Foam solutions released from AFFF form films on hot fuels. These films spread quickly, cooling the fuel,
and, most importantly, eliminate the transport of hot flammable vapours from fuel to the fire.

Schaefer et al., Know Your Foams, Asia Pacific Fire, 2010, 15-21;
note, the straight chain should denote the fluorosurfactant and
the wiggly chain the hydrocarbon surfactant.

Films might be 40 μm in thickness; i.e.,

comparable to hair diameter.

• The spreading of films is driven by a very low surface tension of AFFF, often as low as 16 mN m-1 (compare
with water of around 72 mN m-1, and typical shampoos of more than 30 mN m-1).
14
• Film formation does not operate in fire extinguishment by fluorine-free foams
Outline
• PEFORMANCE: What is meant by performance of firefighting foams? How is
it measured and how is it used in equipment design and procurement?
• ENVIRONMENT: What are the issues with legacy PFOS, C8 and C8/C6
fluorotelomer-based foams? What type of foams will matter in 2020s? How
are these foams called and why?
• PERFORMANCE versus ENVIRONMENT and HEALTH: How do these properties
stack against each other for two groups of modern foams: fluorine-free
foams and high-purity C6 fluorotelomer foams? Do we foam enough data to
make a fair comparison? What measurements are we missing? The
precautionary principle.

15
 Environment
What differentiates the AFFF and F3 is the presence of fluorosurfactants. Shampoos, soaps and other cleaning
agents contain similar surface-active compounds, albeit with hydrogen replacing fluorine. The presence of
fluorosurfactants gives AFFF a unique (and probably irreproducible) set of properties.

Legacy PFOS aqueous film

forming foam (legacy AFFF)

• C8F17SO3-
• Tail, C8C17-, oleophobic and hydrophobic at the same time, only likes to be in the air
• Head,-SO3-, hydrophilic, likes to be in the aqueous phase
• Perfluorooctane sulfonate (PFOS); perfluoro means that all hydrogen atoms are replaced by fluorine
• Main component in all foam formulations produced by 3M
• Persistent, bioaccumulative and toxic; main contaminant in water
• Withdrawn from production by 3M in 2002
• Placed in Annex B of the Stockholm Convention in 2009, and subjected to plethora of national regulations
• Produced in a non-selective electrochemical fluorination; impurities
include shorter and longer chains, branched molecules, as well
oxidation products, such as PFOA (perfluorooctanoic acid,
C7F15COOH; placed in Annex A of the Stockholm Convention in 2019) 16
Environment
While PFOS and PFOA-impurity are the most infamous PFAS (per- and polyfluoroalkyl substances) included in
historical (legacy) formulations of AFFF, neither are present in modern firefighting foams, except for restricted
manufacturing in China. PFOS and their congeners (similarly looking molecules) constitute major environmental
pollutants that we all hear in media, at least once a week.
• PFOS/PFOA contamination resulted from years of firefighters’ training at airports and defence bases, lack of
collection of run-off water and its disposal. Australian coastal cities often lie on aquifers, promoting the
spread of pollution. (3M)
• In addition to PFOS foams, some legacy formulations were also based on so-called fluorotelomer sulfonates
(FTS) and its derivatives, such as, C8F17C2H4SO3-, with a number of fluorinated carbons of 8 or more (i.e., C10
or C12). (Du Pont)
• In the environment, and to some extend in waste-water treatment plants, FTS decompose to PFOS and other
persistent, toxic and bioaccumulative PFAS, such as perfluoroalkyl carboxylic acids (e.g., PFOS).
• C8 fluorotelomer derivatives first decompose to C8 FTS (C8F17C2H4SO3-), with this species then transforming
preferentially to perfluorooctanoic (PFOA) and perfluoroheptanoic (PFHpA) acids.
• Over the last decade, a great deal of research has been undertaken by fluorosurfactant manufacturers to
produce high-purity C6 fluorotelomer feedstock for making foams. As C6 fluorotelomers and their
derivatives are not as effective as C8 fluorotelomers and their derivatives, the formulators had to contribute
equally to the progress. High-purity C6 fluorotelomers decompose to species that are much less toxic than
the product of decomposition of C8 fluorotelomers. 17
Performance vs Environment and Health
Legacy AFFF
• PFOS (3M, contaminated with PFOS)
• C8 fluorotelomers (Du Pont)
• Mixtures of C6/C8 fluorotelomers
(Dynax, Chemours, Chemguard)

Modern AFFF
• High-purity C6 fluorotelomers (Dynax,
Chemours, Chemguard)

18
Environment
Here it how this decomposition works starting from C8 fluorotelomer sulfonamido alkylbetaine, as an example

8:2 FTAB
8:2 fluorotelomer sulfoamido
alkylbetaine

FTS

PFOA PFHpA

Legacy C8 fluorotelomers are not good news for the environment

19
Outline
• PEFORMANCE: What is meant by performance of firefighting foams? How is
it measured and how is it used in equipment design and procurement?
• ENVIRONMENT: What are the issues with legacy PFOS, C8 and C8/C6
fluorotelomer-based foams? What type of foams will matter in 2020s? How
are these foams called and why?
• PERFORMANCE versus ENVIRONMENT and HEALTH: How do foam properties
stack against each other for two groups of modern foams: fluorine-free
foams and high-purity C6 fluorotelomer foams? Do we have enough data to
make a fair comparison? What measurements are we missing? The
precautionary principle.

20
Environment
Classes of high-purity C6 fluorotelomers, reversed-engineered from analysis for concentrates
T-type (for the thio group): (i) fluorotelomer thioamido sulfonates and (ii) fluorotelomer thiohydroxy ammonium

SA-type (for sulfonamido group): (iii) fluorotelomer sulfonamido betaines, and (iv) fluorotelomer sulfonamido
amines

21
Environment
Classes of high-purity C6 fluorotelomers, reversed-engineered from analysis for concentrates
B-type (for the betaine group): (v) fluorotelomer betaines

22
Performance vs Environment and Health
We will now focus on comparing on high-purity C6 fluorotelomer AFFF and F3 formulations.

Trade literature often contains tendentious

information, supported by out-of-context and
irrelevant citations.
• Both F3 and high-purity C6 foams pass the same
performance standards, and yet Willson places
them on the opposite side of the performance
spectrum.
• Comparisons involving pre-2014 AFFF
formulations are likely to comprise legacy AFFF.
Comparisons between legacy AFFF and F3 are
irrelevant and misleading.
• Comparisons that release no names of the tested
foams cannot be reproduced and represent poor
science.
• Likewise, comparison that give no purity of C6 in
AFFF formulations and present no information on
fluorine content in the tested C6 fail the probity
and QA tests.
The table formulates a convenient framework for rigorous data-driven comparisons in future.
However, such comparisons must satisfy the requirements itemised on the text column on
the right-hand side of this slide.

23
Willson, Are Society’s Expectations Being Met by Fluorine Free Foams (F3)?, The Catalyst JOIFF, Q3, 2019, 24-29
Performance vs Environment and Health
What formulations matter?

Legacy AFFF • Important to understand the difference for

• PFOS (3M, contaminated with PFOS) water contamination

• C8 fluorotelomers (Du Pont) • No point to compare the performance,

• Mixtures of C6/C8 fluorotelomers environment and health effects of F3 with
(Dynax, Chemours, Chemguard) legacy AFFF (if the driver is to identify the
best foams)

Modern foams • How do we know which AFFF are we

dealing with? Industry does not seem
• AFFF: high-purity C6 fluorotelomers forthcoming to release the compositions.
(Dynax, Chemours, Chemguard)
• F3 24
 Performance vs Environment and Health

Use 19F NMR (nuclear magnetic resonance)

to identify first the high-purity C6
formulations!
Three peaks in this region confirm C6
formulations.
Two peaks (or more) indicate that these
manufacturers are using a mixture of
different C6 surfactants.
Three manufacturers now produce high-
purity C6 fluorotelomers.

Snow et al., Quantification of Fluorine Content in AFFF Concentrates, NRL/MR/6120--17-9752, 2017, https://apps.dtic.mil/dtic/tr/fulltext/u2/1040969.pdf 25
(accessed on 28 Oct 2019)
 Performance Solberg, RE-HEALING RF3, 3 %
Pan shape and Application
Test Standard Fuel Preburn Extinction
size rate density
m2 L/(min m2) s s

Unleaded Will not meet viscosity specification,

MilSpec Circular, 2.6 2.91 10 30
gasoline no F3 passed MilSpec
Commercial
UL 162 F3 Square, 4.65 2.46 60 300 Yes
heptane
Commercial Not applicable (passed when
UL 162 AFFF Square, 4.65 1.64 60 180
heptane tested)
ICAO Level B Circular, 4.5 Kerosene 2.5 60 60 Yes

ICAO Level C Circular, 7.3 Kerosene 1.56 60 60 Yes

• RE-HEALING RF3, 3 % foam concentrate is both UL Listed and FM Approved for use in automatic sprinkler
systems at exactly the same application rates as AFFF.
• Well-formulated AFFF (high-purity C6 fluorotelomer) should meet all standards, UL 162 would require
fluorine content of about 0.7-1.1 % in 3 % concentrate, twice as much for MilSpec foams. 26
Performance vs Environment and Health
• Standards need to be modified to allow both high-purity C6 AFFF and F3 formulations to compete
on the same footing. What is good for the goose is good for the gander!
• Well performing F3 formulations, such as Solberg RF 3 %, display high-viscosity due to the
presence of diutan gum (~ 9 Pa s). This high-viscosity of the concentrate can be easily taken into
consideration when designing the new induction and mixing systems.
• For designing new systems, the requirement for low-viscosity formulations embedded in MilSpec
should be revisited. This requirement has led to poorly chosen F3 formulations for testing (such
as Solberg’s low viscosity formulation in NRL/MR/6123—19-9895). It seems that, it is the viscosity
requirement, not the 30 s extinguishment time in this standard, that will prevent future F3
formulations to pass the standard.
• Standards should not differentiate between testing of AFFF and F3 formulations. This is done in
EN 1568 and ICAO. UL 162 needs to be modified to require testing of both AFFF and F3 to the
same application rate densities and burnbacks.
• Standardisation bodies should require manufacturers of high-purity C6 formulations to submit
high-resolution 19F spectra to ascertain purity of C6 formulations. Foam formulators should place
the spectra on their web sites, together with the fluorine content in their foam concentrates. 27
 Performance vs Environment and Health
F3 require higher application rates to maintain the same margin of safety, as their critical application
(i.e., minimum foam flow to extinguish a fire) is higher. Extinguishment by F3 may take longer; i.e., F3
require larger suppression systems for the same hazard.

MilSpec F3

Safety margin Safety margin

Critical flow rate Design concentration

Design concentration Design concentration must be higher for the
Critical flow rate (for illustration only) same safety margin
28
Snow et al. Fuel for Firefighting Foam Evaluations: Gasoline vs Heptane, NRL/MR6123—19-9895
 Performance vs Environment and Health

Legacy foams scale linearly;

i.e., if the same application
flux density is used on a big
fire as on a test fire, it will take
the same amount of time or
less to extinguish a big fire as
the small one. There is no
data on scaling for high-purity
C6 telomer foams and limited
data for F3 (mainly on RE-
HEALING foams).

Scheffey et al. Performance Analysis of Foam Agents Required to Combat Liquid Fuel Hazards, 29
https://pdfs.semanticscholar.org/f31f/5bf7703620640a19ff6a49d5c53d1a548e66.pdf, accessed on 28 Oct 2019
Performance vs Environment and Health
Unresolved problems
• Scaling (how test results scale up to large real-world fires). While it is believed that the high-purity
C6 AFFF will perform as good as the legacy AFFF, there is no scaling data for high-purity C6 AFFF.
Few measurements exist for F3 either, indicating that the scaling might not be linear for F3.
o Legacy AFFF tend to pick up more fuel (when the foam hit hot fuel surfaces) but produce less
flammable foam-fuel mixtures. If there are problems, they will show in the scaling of both
foams.
• High-temperature performance (35 °C): There is no data how modern AFFF and F3 perform in hot
environments. All test protocols assume northern climate. The air temperature matters more
than fuel temperature.
• Comparative studies between modern AFFF and F3 must provide 19F NMR traces and their fluorine
content, to ascertain the testing of high-purity C6 fluorotelomer formulations. There is no point to
perform experiments on F3 to compare the findings with the legacy AFFF.
30
 Performance vs Environment and Health
Biodegradation of C6 fluorotelomers in the environment – complicated mechanisms but a simple
message – C6 fluorotelomers biodegrade slowly in the environment to perfluorobutanoate,
perfluoropentanoate and perfluorohexanoate (PFBA, PFPeA and PFHxA).

You start And end

with this up with
these

31
D’Agostino and Mabury, Aerobic biodegradation of 2 fluorotelomer sulphonamide …, Environmental Toxicology and Chemistry 36, 2017, 2012-2021.
 Performance vs Environment and Health
… similar results for activated sludge and measurements in plant handling industrial waste – low
conversion and the same products (from the small amount of converted C6 fluorotelomer) …

Days
32
Wang et al., 6:2 fluorotelomer sulfonate aerobic biotransformation in activated sludge of waste water treatment plants, Chemosphere 82, 2011, 853-858.
 Performance vs Environment and Health
Hydrogeological fractionation of PFAS – long chain
PFAS preferentially adsorb on particles, short chain
preferentially fractionate to water
• Low concentration of long chain PFAS in water
– underlined in red – these species
preferentially adsorb on particles
• High concentration of short chain PFAS in
water – underlined in blue – these species
preferentially fractionate to ground water; i.e.,
short chain PFAS spread faster in ground water
• This behaviour, as observed at a legacy AFFF
site, is supported by fractionation coefficients
measured in the lab.
• The ratio of PFOS to PFHxS derivatives in 3M
formulations was approximately 3:1.
• In water at this contaminated site, it is
approximately 1:8! 33
Backe et al., Zwitterionic, Cationic, and Anionic Fluorinated Chemicals …, Environmental Science and Technology 47, 2013, 5226-5234.
Performance vs Environment and Health
• F3 achieve their performance due to the presence of high amounts of gums, such diutan. When
released to water, aerobic bacteria consume F3 components quickly, leading to high BOD, oxygen
depletion and suffocation of water organisms. In other words, the present high-performance F3 have
high acute toxicity. Aqueous environment recovers quickly.
• F3 are safe to dispose in waste water treatment plants.
• As presently known, modern AFFF include low toxicity chemicals. In the environment, C6 fluorotelomers
decompose to low-toxicity short-chain persistent and mobile perfluoro carboxylic acids, mainly to
perfluorohexanoic and perfluoropentanoic acids (PFHxA and PFPA).
• Long-time exposure of organisms to PFHxA and PFPA and long-term accumulation of these species in
food chain are unknown. Precautionary principle must apply – if there are threats of serious or
irreversible environmental damage, lack of scientific certainty should not be used as a reason for
postponing measures to prevent environmental degradation.
Preston, The Judicial Development of the Precautionary Principle, Environmental and Planning Law Journal 35, 2018, 123-141.

• Modern AFFF must not be disposed in water treatment plants, as conversion of C6 fluorotelomers to
PFHxA and PFHpA is low, and unconverted PFAS species contaminate sludge and treated water.

Let’s unpack some of these considerations. 34

Performance vs Environment and Health
• Based on the limited information available, it is unclear whether fluorinated alternatives are
safe for humans and the environment.
Wang et al., Fluorinated alternatives to long-chain perfuoroalkyl carboxylic acids …, Environment International 60, 2013, 242-248.

• The presently available information indicates that, chronic toxicity and bioaccumulation of
PFAS alternatives and their decomposition products is significantly less than that of legacy
PFAS, for example, for the decomposition products
o (Genotoxicity/Mutagenicity) The toxicity was in general low and increased with chain
length, and the toxicity of PFHxA was about ten times lower than PFOA
Danish EPA, Short-chain polyfluoroalkyl substances (PFAS), https://www2.mst.dk/Udgiv/publications/2015/05/978-87-93352-15-5.pdf, accessed
on 29 Oct 2019;

o (Organ toxicity) Effects observed in the liver in studies with PFHxA and PFBA were
generally mild and reversible
NICNAS, 2017, as cited in
https://www.turi.org/Our_Work/Policy/Toxics_Use_Reduction_Act/Councils_and_Committees/TURA_Science_Advisory_Board/PFAS_information
_reviewed_by_the_Science_Advisory_Board/Draft_EHS_Summary_for_PFHxA, accessed on 29 Oct 2019

35
Performance vs Environment and Health
• And on the toxicity of alternatives themselves
o (Toxicity in zebrafish embroys) These values [LC50] were both higher than those of PFOS,
supporting the notion that 6:2 FTAB is less toxic than PFOS to zebrafish embryos. …
Collectively, our data suggest that 6:2 FTAB exposure can induce cell apoptasis, oxidative
stress, and immunotoxicity, thus highlighting the developmental toxicity of 6:2 zebrafish
embryos.
Shi et al.. 6:2 fluorotelomer sulphonamide alkylbetaine …, Aquatic Toxicity 195, 2018, 24-32.

o (Toxicity in turbot) Taking into account that Forafac 1157 appeared to be less toxic than
PFOS …, this mixture could be considered as a more environmentally acceptable PFOS
alternative for the use in AFFFs. However, long-term effects of this mixture as well as
effects after prolonged exposure to lower concentrations should be addressed.
Hagenaars A. et al., The search for alternative aqueous film forming foams (AFFF) .., Aquatic Toxicity 104, 2011, 168-176.

36
Take-Home Messages
Intense competition between proponents and opponents of modern AFFF (high-purity C6 fluorotelomer-based) and F3
blurs simple messages.
• Modern AFFF and F3 meet the same performance standards, except for MilSpec. One must select foams that have
test certificates (ICAO: Level C, EN 1568-3: 1A or 1B). We must recognise equally the developers of modern AFFF
and F3 formulations for the progress they have made in the field.
• Modern AFFF decompose to persistent and mobile perfluorocarboxylates (PFBA, PFPA and PFHxA).
o Literature indicates low bioaccumulation and low chronic toxicity of C6 fluorotelomers and their
decomposition products.
o Precautionary principle applies, as long-term exposure and accumulation of C6 and their decomposition
product in food chain are unknown.
o Foam solutions of modern AFFF must not be disposed in waste water treatment plants. At present, this
means capturing, separating and then incinerating the spent C6 fluorotelomers, an expensive undertaking. In
future, this may mean, developing technologies for recycling C6 fluorotelomers back to foams, or converting
them to other value-added chemicals, such as fluoroplastics.
• Don’t believe everything you hear or read in trade literature.
o Demand release of all data and do not accept performance comparisons of F3 with legacy AFFF, demand
release of the names of the tested foams.
o The same fire-performance standards should apply to both modern AFFF and F3 (change needed in UL 162).
o High-quality measurements are needed on scaling and temperature performance of both modern AFFF and
F3.
o Firefighting systems can handle high-viscosity F3 concentrates (change needed in MillSpec).
37
 Acknowledgements
While all mistakes and misinterpretations are mine, I would like to thank the following people for discussions, email
communication and data provided to me
• Mr Ted Schaefer, Consultant, Inventor of RE-HEALING foams, Australia (former Master student at the University of
Newcastle, Australia, co-supervised with Professor Eric Kennedy)
• Professor Bruce Gardiner, Murdoch University (former PhD student at the University of Newcastle, Australia, co-
supervised with Professor Graeme Jameson)
• Dr Amer Magrabi, Director, Vortex Fire (former PhD student at the University of Newcastle, Australia, co-supervised
with Professor Graeme Jameson)
• Mr David Meyer, Managing Director, Orion, Australia (present Master student at Charles Darwin University, co-
supervised with Dr Luis Herrera Díaz)
• Dr Ramagopal Ananth, Chemical Engineer, Naval Research Laboratory, USA
• Ms Katherine Hinnant, Chemical Engineer, Naval Research Laboratory, USA
• Dr Chang Jho, Vice President R&D, Dynax Corporation, USA
• Adjunct Professor Jimmy Seow, Director, ENVIRON, Australia
• and many others

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