Aiding the transition to fluorine-free firefighting foams

Ramboll has provided technical support to the European Commission in the preparation of official European Union (EU) guidance for transitioning to fluorine-free firefighting foam, under a service contract with the European Commission and as a sub-consultant to WSP.

Creating actionable technical support

The project focused on translating regulatory obligations and existing guidance into clear, practical technical support to assist operators and competent authorities in implementing the transition from firefighting foams containing per- and polyfluoroalkyl substances (PFAS) to fluorine-free alternatives. By distilling complex legal requirements and technical recommendations into actionable steps, the guidance aims to ensure that those responsible for compliance are equipped with the tools and understanding necessary to navigate the shift away from PFAS-containing firefighting foams efficiently and effectively.

The EU has introduced restrictions on PFAS in firefighting foams under the REACH (registration, evaluation, authorisation and restriction of chemicals) Regulation, including bans, transition periods, emission minimisation requirements, and detailed obligations for the handling of PFAS-containing foams, waste, and wastewater. In parallel, the POPs (persistent organic pollutants) Regulation imposes bans and strict limits on specific PFAS listed under the Stockholm Convention, with time-limited exemptions.

Guidance with global relevance

While developed as EU guidance, the document also has useful, practical relevance beyond the EU, particularly given the existing and emerging obligations under the Stockholm Convention on Persistent Organic Pollutants that apply to all of the relevant international parties.

The REACH restriction on PFAS in firefighting foams establishes limitations on both the marketing and use of foams containing PFAS above defined thresholds, with sector-specific transitional periods and additional requirements such as the containment of releases, the development of management plans, adequate labelling, and obligations for the destruction or irreversible transformation of PFAS-containing waste. These provisions are particularly relevant for users of aqueous film forming foam (AFFF) historically applied in class B fires (those involving flammable liquids and gases, such as petrol, oil, diesel, paints, and alcohols) including installations in civil aviation, Seveso sites (known as COMAH in the UK), offshore facilities, and public fire services.

Translating regulatory obligations into practical support

The guidance builds on and consolidates existing international, EU, and national guidance documents, technical studies, and regulatory assessments that were available at the time of drafting. The document does not introduce new legal requirements; rather it translates regulatory obligations and existing guidance into practical, technical support to aid the transition away from firefighting foams containing PFAS to fluorine-free alternatives. It is potentially relevant to any organisation working on the transition, especially operators and competent authorities with implementation of the requirements.

The guidance was developed alongside a Member State steering group that provided oversight and input throughout the process. Targeted stakeholder consultation was also conducted with experts and key practitioners to ensure that the guidance reflects operational realities and addresses key challenges associated with the phase-out of PFAS containing firefighting foams.

What the guidance provides for operators and authorities

Users of this guidance will find:

• Structured, non-prescriptive technical support covering the full transition process
• Background information on PFAS use in firefighting foams such as AFFF
• An overview of applicable EU legal requirements
• Practical considerations for identifying PFAS-containing foams
• Guidance for managing existing stocks
• Assistance for classifying and disposing of PFAS-related waste
• Information on cleaning and decontaminating firefighting infrastructure
• Support for selecting and implementing fluorine-free alternatives
• Illustrative case studies
• Decision support tools
• References to established analytical methods to support informed decision making while allowing flexibility for site specific, sector specific, and national circumstances

The full guidance can be found on ECHA’s website: https://echa.europa.eu/documents/10162/6956102/EU_guidance_for_transitioning_to_fluorine-free_firefighting_foams_en.pdf/24d79e79-a1af-dd0c-0b31-bdc2f78f08fe