DOD and FAA Approve Second Fluorine-Free Firefighting Foam for Part 139 Airport Use
On February 8, the U.S. Department of Defense (DOD) identified BIOEX ECOPOL A3+ MIL-SPEC as the second fluorine-free firefighting foam (F3) agent that meets the department's F3 performance standards. With DOD officially listing the product in its Qualified Product List (QPL) today, BIOEX ECOPOL A3+ becomes the second F3 agent to be approved by the Federal Aviation Administration (FAA) for use at Part 139 certificated airports. Based on our conversations with the U.S. Navy and FAA, we could potentially see one other F3 product to be listed in the QPL this month. However, any additional products beyond that are not expected to be listed until June 2024, at the earliest.
Since September 2023, only one F3 product'”the SOLBERG® 3% MIL-SPEC Synthetic Fluorine-Free Foam (SFFF)'”has been available to airports seeking to make the transition. DOD and FAA's approval of a second foam is a positive development in the effort to transition to F3 agents and away from aqueous film forming foam (AFFF). However, questions still remain over the most appropriate and cost-effective method for switching to F3 because of the lack of clear guidance from FAA and the U.S. Environmental Protection Agency (EPA). AAAE continues to press FAA, EPA, and the Hill for clarity on these important transition-related questions.
AAAE and its PFAS Working Group will be hosting its next meeting on Thursday, February 15, at 3 p.m. ET. We will be discussing the ongoing F3 transition effort and other PFAS-related issues. You can participate in the meeting by reaching out to Megan Eisenstein at megan.eisenstein@aaae.org. The group has been meeting regularly to facilitate discussion among airports on this important issue.
Background. Over the past several years, DOD, in coordination with FAA, evaluated F3 agents and developed a new military specification'”known as minimum performance standards'”to facilitate the transition to F3 agents after significant concerns have been raised about PFAS-containing AFFF, which FAA has required airports to use for decades. In January 2023, the U.S. Navy published a military specification for F3 agents ('F3 MIL-SPEC'). These new performance standards allowed F3 manufacturers to submit their products for DOD testing and certification. Demonstrating that an F3 product meets the F3 MIL-SPEC means the agent will be added DOD's QPL. In addition, FAA permits Part 139 airports to substitute AFFF for any F3 agent that meets the F3 MIL-SPEC and is listed in the DOD's QPL.
Status of F3 Testing and Approvals. According to the U.S. Navy, a total of seven F3 products were submitted to DOD for testing and certification after January 2023 when the F3 MIL-SPEC was released. Among these products, only one F3 agent met the performance standards and passed conformance testing without any issues or modifications to the foam. In September 2023, DOD listed this foam, the SOLBERG® 3% MIL-SPEC SFFF, in the QPL, making it the first F3 agent to be approved for use at Part 139 airports. In December 2023, another two F3 products were submitted to DOD for testing and certification.
It remains to be seen how many additional F3 products will ultimately meet the F3 MIL-SPEC and be added to the QPL. The U.S. Navy has informed AAAE that we could see another F3 product approved this month; however, beyond that, no other products are expected to be listed until summer 2024, at the earliest. As for the reasons for the delays, reports are that F3 manufacturers are still modifying their products after encountering issues during testing.
Key Points of Emphasis on F3 Transition. With two F3 products listed in the QPL, it is important to remember some key points of emphasis as your airport considers whether and how to make the transition to F3. FAA published three documents in 2023 relating to this question: (1) Part 139 Cert Alert No. 23-01, dated January 12; (2) 'Aircraft Firefighting Foam Transition Plan,' dated May 8; and (3) Advisory Circular, 150/5210-6E, 'Aircraft Fire Extinguishing Agents,' dated November 27.
Based on the documents and conversations with subject matter experts, we have put together the following key points of emphasis that airports should know:
F3 Transition Not Mandatory: Part 139 airports will not be required by the agency to transition to F3 and may continue to use AFFF. However, there are two other driving factors that may require airports to transition in the near term. First, some states have already enacted legislation that prohibits the use of AFFF after a specific period of time. Second, manufacturers are beginning to phase out the sale and production of AFFF, which may result in some airports having to make the transition sooner.
Part 139 Airports Limited to Certified F3 Agents: Part 139 airports may only use F3 products that have been found to meet the F3 MIL-SPEC; such agents will be listed in DOD's QPL, which can be found here.
Compatibility with Other F3 Agents: F3 agents lack compatibility with other F3 agents, which means they cannot be mixed together. Airports will be expected to ensure that F3 from one manufacturer is not added or mixed with F3 from another manufacturer. FAA recommends that airports have sufficient quantities of the certified F3 product that the airport chooses to use to mitigate the risk of having to procure an alternative F3 product and potentially mixing F3 from different manufacturers.
Understanding How F3 Performs: F3 and AFFF perform very differently from one another, and the appropriate tactics and techniques to successfully apply F3 are not the same. FAA emphasized that because F3 does not contain fluorinated surfactants, firefighters' techniques, application, and foam blanket management will be critically important to ensure the fire is contained and to prevent re-ignition. This means airports need to ensure their firefighters are well trained on how to properly use F3. In November 2023, FAA hosted a 'Fluorine Free Foam (F3) Transition Awareness Webinar' that significantly focused on the performance of F3 for training purposes. A recording is available here.
Use of Input-Based Testing Systems for F3: In its guidance, FAA recommends that Part 139 airports continue to use input-based testing equipment to ensure that the foam proportioning system on their ARFF vehicles is working properly, regardless of the foam being used. Testing of the ARFF vehicle is a requirement that airports must perform under Part 139.
Considerations for Transition Planning: In its transition plan, FAA noted that each ARFF vehicle would need to be taken out of service for five days or more to make the transition. This may require some airports to borrow or rent an ARFF vehicle to maintain index requirements. The agency also outlined a series of other factors that the agency believes airports should consider as they look to transition to F3, including the availability and storage of new foam, storage for unused AFFF product and any cleaning rinsate, potential state 'takeback' programs for AFFF that may be available, and state and local environmental requirements, among many others.
Decontaminating ARFF Equipment: Pursuant to a congressional directive, FAA was required to outline best practices for the decontamination of ARFF equipment in its transition plan. Unfortunately, the plan did not provide any meaningful recommendations to airports. FAA noted that it is hard to determine the level of residual PFAS in ARFF equipment and a method of testing for PFAS has not been identified. The agency has informed AAAE, however, that they plan to make available to airports protocols that DOD is developing for decontamination and cleaning of ARFF vehicles. A timeline for release has not been provided.
Disposal of AFFF and PFAS-Containing Materials: Within the next few months, EPA is expected to update its interim guidance on the destruction and disposal of PFAS and PFAS-containing materials, such as AFFF. The agency's guidance was originally released for public comment in December 2020. In comments filed in early 2021, AAAE emphasized the lack of clarity for airports in navigating this area and the need for reasonable destruction and disposal options. However, some EPA officials have already publicly signaled that the agency still does not have significant data to provide 'more definite recommendations' on possible disposal and destruction methods.
What's Next? AAAE will keep our members apprised of any additional F3 agents that are approved and listed in the DOD's QPL. We will also continue to work with and press FAA, EPA, and lawmakers to ensure that airports have the resources, time, and guidance they need to transition from AFFF to F3 agents, especially with many of the important environmental questions that remain unaddressed by the federal government.
Resources on F3 Transition
DOD's Qualified Products List for F3 Agents Certified Under MIL-PRF-32725
FAA's 'F3 Transition for Aircraft Firefighting' Website
FAA's 'Fluorine Free Foam (F3) Transition Awareness Webinar,' held in November 2023
FAA's Advisory Circular, 150/5210-6E, 'Aircraft Fire Extinguishing Agents,' dated November 27, 2023
FAA's 'Aircraft Firefighting Foam Transition Plan,' dated May 8, 2023
FAA Part 139 Cert Alert, 'New Military Specification for Performance-Based Standards for Fluorine-Free Aircraft Fire Fighting Foam,' dated January 12, 2023
MIL-PRF-32725, 'Fire Extinguishing Agent, Fluorine-Free Foam (F3) Liquid Concentrate, For Land-Based, Fresh Water Applications,' dated January 6, 2023
