Aisha Farooq, Deputy Editor of Fire & Risk Management (F&RM), the journal of the Fire Protection Association, looks at the latest measures to phase out ‘forever chemicals’.
Aisha Farooq, Deputy Editor, F&RM
Interest in the everlasting nature of forever chemicals is accelerating at an unprecedented rate. With more and more manufacturers announcing their plans to phase out the use of per- and polyfluoroalkyl substances (PFAS) chemicals in their most popular and effective products, the debate around ethics and innovation in science is also reaching its peak.
From a firefighting perspective, the journey towards phasing out PFAS-containing aqueous film-forming foams (AFFFs) or firefighting foams from everyday firefighting activities has already begun with the Environment Agency (EA) publishing guidance on the restricted use of PFAS in firefighting foams due to the risk of groundwater contamination.
Since 1 January 2023, firefighting foams containing PFOA have only been allowed in sites where all releases can be contained. As of 4 July 2025, all uses will be prohibited.
“Exposure to PFAS can cause environmental contamination and human health risks”
This substantial move supports a new report from the Health and Safety Executive (HSE), in close partnership with the EA and UK Reach, that has analysed the use and persistence of ‘forever chemicals’ in Great Britain. Published in Spring 2023, the Regulatory Management Options Analysis (RMOA) recognises the significant damage that forever chemicals can have on both human health and the environment.
Commonly found in everyday items such as non-stick cookware, cleaning products, and waterproof clothing, these chemicals are “slow to degrade and remain in the environment for many decades”. Exposure to PFAS can cause environmental contamination and human health risks, while their wide use around the world presents an “even greater challenge around their potential management”.
The RMOA on PFAS is the “most comprehensive British analysis of these chemicals ever” and seeks to assess the nature and likely health and environmental risks posed by PFAS and the “most appropriate options” for their management. As Dr Richard Daniels, Director of HSE’s chemicals regulation division, explains: “PFAS are a global issue of concern. We have looked at responses around the world, but it was vital we gathered the right information and evidence on how PFAS are used in Britain specifically.
“This has helped us work out where the right action could be taken to limit the use of PFAS and control exposures to people and the environment in this country.”
The detailed report allows experts and those in charge of UK legislation to have a clearer view of the risks of PFAS to both human health and the environment and come up with possible options in which to identify and minimise those risks. One of the key priorities of the report is for further action to be taken to regulate the use of firefighting foams.
The proposal will be founded on scoping work with stakeholders including industry, firefighters, and those with expert knowledge of alternative foams. Dr Daniels adds: “The reality is that PFAS substances, due to their persistent properties, will continue to be detected for many years – despite measures being taken to limit restrict or ban their use.
“We will now look at the availability and risks posed by alternatives to ensure maximum long-term protections can be gained. “There is evidence of occupational exposure and environmental harm that can come from current firefighting foams, and we can understand the concerns among firefighters.
“We encourage all affected to work with us in the scoping exercise.”
In light of the projected ban on firefighting foams, the popular extinguishing agent, NOVEC 1230, will also be discontinued by 2025. Described as a ‘clean agent’ fire suppression chemical owing to its ability to deploy only naturally occurring gas, the substance is used for special hazard waterless fire suppression as it leaves no residue and is electrically non-conductive. The move by American manufacturer 3M signifies a massive shift in the perception around PFAS use and the marked attempt to balance the use of highly effective substances and their impact on the environment.
Useful against Class A, B, and C fire hazards, this move also opens up renewed concerns over the efficacy of alternatives and whether these replacements will bring their own string of potential issues in the future. As former Technical Director of the FPA, Professor Jim Glockling, outlined in his RISCAuthority document on Migration of foam-enhanced fixed sprinkler and drencher systems to use fluorine-free alternatives: “The challenge to remove fluorine from firefighting foams is not an easy one. Whilst fluorine-free foams might be termed as ‘eco’ or ‘environmentally friendly’, this might misrepresent them.
“Whether man-made or natural, they will have an impact on the environment and there will always be a need to consult the environmental protection authorities regarding their use, especially in areas where groundwater aquifers are the primary source of drinking water.”
Needless to say, the growing concern around the harmful effects of certain manmade substances has opened up a window into the ethical use of forever chemicals in our everyday lives. Arguably, the debate on the ethical use of PFAS is gaining more momentum in the US with the latest studies showing just how far PFAS has entered everyday use.
In a recent article from The Guardian, research into 18 popular types of soft contact lenses in the US has found they contain high levels of fluoropolymer compounds or organic fluorine, which come under the category of forever chemicals – however, the impact they have on eye health is currently unclear. Another study by Harvard University has explored the presence of PFAS in drinking water across numerous states, concluding that higher percentages of these chemicals are found at sites near industrial plants, landfills, and military fire training bases – some media outlets have suggested that these chemicals are “disproportionately polluting Black and Hispanic neighbourhoods”.
The US Environmental Protection Agency (EPA) has already proposed new regulations in which to limit the number of forever chemicals in drinking water, with Michael Regan, EPA administrator, stating: “This action has the potential to prevent tens of thousands of PFAS-related illnesses and marks a major step toward safeguarding all our communities from these dangerous contaminants.”
Following the RMOA, Environment Minister Rebecca Pow said: “By improving our understanding of the potential risks posed by PFAS, we will be better equipped to tackle them. “The HSE’s analysis is a key part of our efforts to protect us from these persistent chemicals – our Plan for Water recognises this, and we will begin developing proposals to restrict PFAS in firefighting foams this year. “This will build on our action to increase monitoring and support a ban or highly restrict specific PFAS both domestically and internationally so that we can reduce the amount of PFAS entering our natural environment.”
Executive Director of the EA, John Leyland, has called the RMOA a “significant milestone in the UK’s efforts to protect people and the environment from the potential impacts of PFAS…We are rapidly expanding our monitoring to build a clearer picture of PFAS chemicals and their potential risks.
“By working closely with our partners, we will broaden our understanding to better inform decision-making so that we can safeguard the public and our environment for future generations,” he said.
It is highly likely that we could see the introduction of more rules and regulations around the use of PFAS substances moving forward. Following the publication of the RMOA, HSE, the EA, and DEFRA will now consider the recommendations and necessary actions are expected to be set out in the UK REACH Work Programme for 2023–24.
This article first appeared in the May 2023 issue of the Fire Protection Association journal, Fire & Risk Management.
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