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Laszlo Komaromi, Senior Technical Officer at the Energy Institute, outlines the key issues around the transition to PFAS-free firefighting foams used in the energy sector. These are discussed in the latest edition of EI Model Code of Safe Practice Part 19: Fire precautions at petroleum refineries and bulk storage installations (EI 19), authored by Paul Watkins and Dr Niall Ramsden, ENRg Consultants, and due to be published in December 2022.*
Per- and polyfluoroalkyl substances (PFASs) are known for their adverse effects on our health and the environment. Some of their derivatives are used to manufacture common household products, and they also have been a key ingredient in industrial firefighting foams used to extinguish petroleum fires at refineries or bulk storage terminals, also known as ‘Seveso sites’.
PFASs, or so called ‘forever chemicals’, are a large group of synthetic, environmentally persistent and potentially toxic chemicals, some of which build up in living organisms through a process called bioaccumulation. PFASs are often classified into two groups according to the length of their carbon chain – long- and short-chain PFASs.
Long-chain PFASs such as perfluorooctanic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), tend to be more bioaccumulative and therefore less safe than other, short-chain PFASs.
PFASs are about to be regulated in the European Union (EU) under proposals from the European Chemicals Agency (ECHA). As a result of Brexit, the UK REACH (registration, evaluation, authorisation and restriction of chemicals) regulation came into effect on 1 January 2021. This regulation retains the key principles of EU REACH; however, the two frameworks operate independently of each other. Therefore, duty holders should comply with both regulations where applicable.
Where are we now?
Most uses of long chain PFASs have been banned or restricted by the UK, the EU and international regulations. For instance, in 2009, PFOS was added to the Stockholm Convention on Persistent Organic Pollutants, to which the UK is a party. This meant that any firefighting foams containing PFOS should have been removed from sites (eg bulk storage sites storing or handling flammable substances) and ethically disposed of before June 2011.
PFOA substances were also added to the Stockholm Convention in 2019. In the UK, the use of foams containing these chemicals is currently limited to class B fires (ie fires involving flammable/combustible liquids), and from 1 January 2023 they will only be allowed in sites where all releases can be fully contained. A total ban on PFOA-containing products is expected to come into effect from July 2025.
In order to comply with regulatory requirements following the phase out of PFOS and PFOA, manufacturers have introduced alternative foam products that contain short-chain (‘C6’) PFAS compounds, most of which are still permitted under EU/UK law but will be subject to a complete ban when the ECHA proposals are adopted. Thus, manufactures and duty holders are now facing a ticking clock due to an impending ban on all PFASs, to be brought upon by an EU-wide initiative.
What are the key challenges?
Different foam applications have different performance requirements depending on a range of factors, such as the type of substance and potential fire involved. Consequently, there is no single fire performance test or standard that suits all types of applications.
In general, manufacturers/operating companies should ensure that the performance of the foam application meets the requirements of a standard relevant to the application and that the test method used has been verified for that application. For instance, foam applications for refineries or bulk storage terminals might be required to meet the Large Atmospheric Storage Tank Fires (LASTFIRE) Standard Test Protocol and also EN 1568 or UL 162. A series of small- and large-scale performance tests of PFAS-free foams were undertaken by LASTFIRE, the results of which are reported in the new edition of EI 19.
For operating companies, the removal and appropriate disposal of PFAS-containing foam stock is an area of ongoing development. This includes decontaminating the existing fire suppression infrastructure, which may involve the use of specialised chemicals. The decontamination procedure is subject to regulatory change, as limits for residual PFAS contamination levels are still being set, and new, more efficient, disposal methods being developed.
Furthermore, the transition to PFAS-free foams requires careful preplanning. For instance, PFAS-free foams may require different discharge/application rates and application methods, and might require slight modifications to be made to existing foam supply systems. Duty holders should take into account these considerations while ensuring that adequate site-specific fire response strategies are in place and that they fully comply with local regulatory requirements.
What are the next steps?
The UK is still awaiting the outcome of a regulatory management options analysis (RMOA) being conducted by the Environment Agency and UK Health and Safety Executive (HSE). The aim of the RMOA is to investigate the environmental and human health risks posed by PFAS and to identify the most appropriate options for managing them under UK REACH.
Following the results of both consultations, ECHA and HSE may decide to impose stricter measures on the use of PFASs, assuming there is sufficient supporting evidence. Some EU member states are currently working on a proposal to further restrict the use of PFAS, which is expected to be submitted to ECHA in January 2023. The current proposal is to have a total ban in firefighting foams with a maximum transition period of 10 years for Seveso sites.
The European Commission has committed to phase out all ‘remaining’ PFASs, with exceptions made to specific applications where they prove to be ‘irreplaceable and essential to society’. However, it is unclear at this time what these specific applications might entail.
*The latest edition of EI 19 will be available through the following link once it is published in December: Energy Institute (2022) Model Code of Safe Practice Part 19: Fire precautions at petroleum refineries and bulk storage installations, 4th edition.
The views and opinions expressed in this article are strictly those of the author only and are not necessarily given or endorsed by or on behalf of the Energy Institute.