PFAS are a diverse group of compounds resistant to heat, water, and oil. For decades, they have been used in hundreds of industrial applications and consumer products such as carpeting, apparel, upholstery, certain food paper wrappings, metal plating, and firefighting foams.
AFFF (aqueous film-forming foam) is a significant source of PFAS contamination in and around airports. The two most concerning PFAS compounds found in AFFF are PFOA and PFOS. Since at least the 80s, research has found links between PFOS and PFOA and a number of health problems, such as: chronic kidney disease, thyroid issues, certain types of cancers, etc.
For decades, AFFF has been used by commercial airports and military bases to respond to fire emergencies and during training. AFFF can seep into the ground to contaminate soil and ground water. AFFF that enters the storm drainage system can lead to contamination of the public water supply when it is sent to the local water treatment plant. (Traditional water treatment processes do not remove PFAS.)
Since AFFF has a lengthy shelf life, many airport operators have built up stockpiles over the years. Consequently, PFAS contamination can also be due to improper handling of AFFF supplies, or a result of degraded storage systems. Remember, too, that PFAS doesn’t degrade naturally. Even if AFFF hasn’t been used for decades, the contamination can remain.
The FAA has historically required that AFFF be used in fighting aviation fires. Despite claiming that fluorine-free foams do not provide the same level of fire suppression as AFFF, this mandate is to be phased out by October 4, 2021. In the meantime, Part 139 airports must continue to use AFFF for emergency response. They are also required to test their AFFF systems during regular maintenance. This testing involves the release of AFFF.
In 2019, the FAA began construction on a research facility specifically for developing a fluorine-free replacement to AFFF. At the same time, the DOD is doing research into fluorine-free fire-fighting foams as well.
Even though airports are a common source of PFAS contamination, most states do not require airports to do routine testing. That’s beginning to change. For example, in 2019, California issued orders giving airports 60 days to develop a testing plan.
Organizations that specialize in environmental and personal injury litigation are also targeting airports. It remains to be seen whether the FAA’s requiring the use of AFFF will be an adequate defense. Some experts don’t think so.
Whether it’s to respond to new regulations or pending litigation, testing can help you be prepared.
The latest research provides new insights into PFAS contamination and its effects on the environment and public health. Not surprisingly, the regulatory landscape is constantly shifting in response.
We’d be happy to schedule a personalized briefing for your team to bring you up-to-date on all the latest details affecting airport operations. Just give us a time and date that works for you.
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