The fiscal year 2020 National Defense Authorization Act required the Department of Defense (DoD) to phase out by October 1, 2024 the use of per and polyfluoroalkyl substances (PFAS) based aqueous film forming foams (AFFF) for firefighting at military installations. Over the last few years there has been tremendous investment in PFAS-free alternatives to AFFF.
The purpose of this project was to improve the ability of the DoD to make informed, efficient choices regarding the use of PFAS-free alternatives to AFFF by strengthening and building consistency in the approaches used to identify, compare, and adopt PFAS-free alternatives.
The ultimate goal of this research project was to strengthen and expand assessment methods to better support government and industry in making informed choices of high-performing, safer, and more sustainable chemicals, products, and processes. Employing improved assessment methods and addressing barriers to commercialization and adoption can improve the long-term results of assessments.
This report summarizes the work in the four attached annex reports for this project on the following three research objectives:
Technical Approach to Research Objective 1, Understanding Gaps
Evaluations of alternatives were required to meet four criteria to be considered a comprehensive alternatives assessment and included in this review:
Existing alternatives assessments were reviewed against two seminal alternatives assessment frameworks: the U.S. National Research Council’s, A Framework to Guide Selection of Chemical Alternatives and the Interstate Chemicals Clearinghouse’s Alternatives Assessment Guide Version 1.1.
Technical Approach to Research Objective 2a, Safer Alternative
The project team developed specific criteria to evaluate and determine whether alternatives are safer as compared to current PFAS-containing AFFF products. The criteria should be considered the minimum requirements for a safer AFFF alternative determination. Criteria are drawn from existing approaches, in particular the Organization for Economic Cooperation and Development’s “Guidance on Key Considerations for the Identification and Selection of Safer Alternatives” and supplemented by others such as the Green Screen Certified for Fire Fighting Foam.
Technical Approach to Research Objective 2b, Fit for Purpose
The project team developed guidance to guide decision-making for the performance of potentially safer alternatives, emphasizing a focus on a fit-for-purpose performance, which underlines the importance of evaluating whether the chemical, material, product, or process of concern achieves sufficient performance; this guidance further expands the thinking around performance as a range and acknowledges important considerations around trade-offs with environmental health and safety performance. Ultimately, the performance evaluation will form part of a broader alternatives assessment process that considers hazard, comparative exposure, economic feasibility, and other factors to compare alternative solutions to replace the chemical, material, product, or process of concern.
Technical Approach to Research Objective 3, Lessons Learned
Reviews of the literature, including peer-reviewed publications and reports, were used to delve deeper into topics and themes that emerged in interviews.
Results of Research Objective 1, Understanding Gaps
Only one alternatives assessment met all four inclusion criteria and was included in this critical review—an alternatives assessment undertaken to support regulatory risk management options by the European Chemicals Agency (ECHA). Future AFFF alternatives assessment can learn from and improve upon the ECHA study in the following ways:
Results of Research Objective 2a, Safer Alternative
The project team developed minimum requirements for a safer AFFF alternative by preparing two lists:
The project team also provided guidelines for applying the minimum requirements.
Results of Research Objective 2b, Fit for Purpose
Six guiding considerations form this performance evaluation process:
The project report includes key questions for each of these six considerations.
Results of Research Objective 3, Lessons Learned
Five primary factors were repeatedly identified as barriers to an effective transition to safer and feasible AFFF alternatives:
Four primary enabling factors that are working to accelerate a transition to PFAS-free alternatives were also identified, including:
Going forward, priority needs to accelerate an effective and broad-based transition to safer PFAS-free firefighting foam. Alternatives include:
Key lessons learned from this work that inform needs and next steps include:
The project team is committed to disseminating work from this project and working with DoD and the SERDP research community to strengthen and expand use of alternatives assessment methods to better support government and industry to accelerate the evaluation and adoption of safer and effective PFAS-free alternatives to AFFF. The project team believes that these approaches can be helpful in addressing other chemical challenges that DoD faces.