DOD Releases AFFF Change-Out Policy for Transition to Fluorine-Free Firefighting Foam

On March 13,  the Federal Aviation Administration (FAA) shared with AAAE the U.S. Department of Defense's (DOD) new guidance on the minimum requirements that the department must follow to ensure aqueous film forming foam (AFFF) is removed from its ARFF vehicles and mobile systems. The policy, which requires at least a single water rinse of the entire system, is part of DOD's broader effort to transition from AFFF to fluorine-free firefighting foam (F3) agents. The guidance is only mandatory for DOD and its components, not Part 139 certificated airports. However, an airport interested in making the transition to F3 agents should consider the policy, along with any relevant state or local requirements, as the airport develops its transition plan.
 
You can read DOD's policy here. DOD has not publicly released the guidance but is expected to do so in the near term. FAA is planning to release a Part 139 Cert Alert that will highlight and include DOD's AFFF change-out policy. FAA's goal is to promote more widespread dissemination and awareness only; the agency does not plan to require Part 139 certificated airports to follow the policy. Release of the guidance follows efforts by AAAE and the airport community to press FAA, EPA, DOD, and the Hill for clarity and guidance on some key issues in order to help the industry make the transition to F3 agents.
 
AAAE and its PFAS Working Group will be hosting its next meeting on Wednesday, March 20, at 2 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. In early 2023, the U.S. Navy published a military specification for F3 agents ('F3 MIL-SPEC'), known as performance standards, that is being used by FAA for certifying F3 products for use at Part 139 airports. To date, two F3 products have been found to meet the F3 MIL-SPEC: the SOLBERG® 3% MIL-SPEC Synthetic Fluorine-Free Foam (SFFF) and the BIOEX ECOPOL A3+ MIL-SPEC. AAAE expects that a third F3 product will be added to the Qualified Product List within the next week or two.
 
With approved products on the market, airports have shifted their attention to understanding how to make the transition, including any modifications that need to be made to ARFF vehicles, protocols for cleaning these vehicles, and disposal of PFAS-containing products, among other things. It is important to note that Part 139 airports are not required by the agency to transition to F3 and may continue to use AFFF, although some states have already enacted legislation that prohibits the use of AFFF after a specific period of time.
 
DOD's Policy on Removing AFFF and Rinsing ARFF Vehicles. The purpose of DOD's guidance is to establish the minimum removal and rinsing requirements to ensure AFFF is removed from all the mobile systems that the department will use for F3 agents. DOD's policy states that for each ARFF vehicle (DOD uses the term 'mobile system') that previously utilized AFFF and will be reused with new F3 agents, the DOD component must:

Completely drain the system of AFFF.
Conduct a single water rinse of the entire system from the AFFF tank through all components and piping to all discharge nozzles, including external equipment that previously contained AFFF.
Empty rinsate from the system and reconfigure it for the selected F3 agent in accordance with the F3 manufacturer's recommendations.
Ensure appropriate spill prevention measures and containment are incorporated into the process to minimize any releases or impacts.

DOD's Policy on Disposal of AFFF/PFAS-Containing Products. According to the policy, DOD requires the disposal of AFFF, rinsate, and other AFFF-impacted materials generated from the removal and rinse process to be conducted in accordance with its July 22, 2023, interim guidance on destroying and disposing of PFAS-containing materials. In the July 2023 guidance, DOD identified the following four commercially available options to destroy or dispose of DOD PFAS-containing materials (in preferred order):

Carbon reactivation units with environmental permits (for used granular activated carbon only);
Hazardous waste landfills with environmental permits;
Solid waste landfills with environmental permits that have composite liners, and gas and leachate collection and treatment systems; and
Hazardous waste incinerators with environmental permits.

Collectively, the March 2024 policy and June 2023 interim guidance provide some useful information for airports to consider when trying to determine how to clean ARFF vehicles and systems and dispose of any AFFF or rinsate generated during the cleaning or rinsing process. Airports are encouraged to carefully review both policies when developing their transition plan.
 
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. If your airport is interested in participating in our monthly PFAS WG meetings to discuss ongoing transition issues, please reach out to out to Megan Eisenstein at megan.eisenstein@aaae.org.
 
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
DOD Memorandum, 'Guidance for the Change Out from Aqueous Film Forming Foam in Mobile Firefighting Systems,' dated March 5, 2024
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
DOD's Memorandum, 'Guidance on Incineration of Materials Containing Per- and Polyfluoroalkyl Substances,' dated July 14, 2023
DOD's Memorandum, 'Interim Guidance on Destruction or Disposal of Materials Containing Per- and Polyfluoroalkyl Substances in the United States,' dated July 11, 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