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:

1. Understand gaps in alternatives assessments for AFFF by reviewing existing assessments.
2. Develop generalizable approaches and guidance to strengthen future alternatives assessments:
3. Understand lessons learned from existing efforts to accelerate the adoption of safer alternatives to AFFF, including barriers and enabling factors.

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:

1. Evaluates commercially available alternatives.
2. Evaluates hazard, cost, and performance attributes (exposure and life cycle attributes optional).
3. Uses standardized assessment criteria to systematically evaluate and compare alternatives to the incumbent.
4. Includes fluorine-free alternatives and the incumbent product (AFFF)/chemical of concern.

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:

• Consider incorporating case studies into alternatives assessment practice.
• Consider broadening the assessment scope (during the problem formulation step) and not limit the functional use for AFFF alternatives to just film forming foams.
• Examine a broader set of hazard endpoints using measured and modeled data sources rather than depending solely on Safety Data Sheets.
• Consider reasonable and foreseeable exposure scenarios and relevant physicochemical properties that would inform the exposure potential of alternatives.
• Support deeper engagement by stakeholders.
• Augment the alternatives assessment in the near future and on an ongoing basis as needed to stay current.

Results of Research Objective 2a, Safer Alternative

The project team developed minimum requirements for a safer AFFF alternative by preparing two lists:

• Part A was a list of substances or classes of substance that a safer alternative cannot include—first among these was PFAS.
• Part B was a statement that a safer AFFF alternative cannot contain ingredients classified as “high” concern for a detailed list of hazard endpoint, e.g., carcinogenicity, acute aquatic toxicity (and others).

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:

1. Determine the function of the chemical/material/product/process of concern for the specific application and understand this function within the production chain.
2. Define the application-specific scenario(s) in which the substance of concern is used and identify alternatives that are suitable for that particular purpose.
3. Establish and/or use performance standards that have been developed independent of the existing chemicals/materials/products/processes of concern (as much as possible) and adjust them based on available alternatives or alternatives on the horizon.
4. Develop and use a range of performance standard benchmarks, from “inadequate” to “sufficient” to “best in class” to evaluate the alternative for the specific application(s).
5. Consider technical performance separately from technical feasibility (feasibility of adoption) of potential alternatives.
6. Consult stakeholders to determine acceptable tradeoffs between performance results and other elements such as environmental health and safety.

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:

1. Transition costs.
2. Lack of knowledge of performance for specific real-world scenarios.
3. Substitution regret. That is, there were lingering questions about the health and safety of alternatives for both workers and the environment given the limited test data on formulations, that needed to be addressed.
4. Standards. Performance standards/specifications, especially the U.S. DoD performance specification (MIL-PRF-2435F(SH)) in the U.S., are hindering adoption of alternatives. In addition, there are an array of standards related to the use of firefighting foams, which has created confusion related to procurement among some entities and has limited continued innovation in fire extinguishment technologies for Class B fires due to costs involved in achieving certifications.
5. Lack of a coherent national transition strategy.

Four primary enabling factors that are working to accelerate a transition to PFAS-free alternatives were also identified, including:

1. “Just do it”—using direct experience and mock exercises to understand performance of alternatives and adoption needs.
2. Financial liabilities with continued use of AFFF.
3. Fit-for-purpose performance standards.
4. Policy mandates.

Going forward, priority needs to accelerate an effective and broad-based transition to safer PFAS-free firefighting foam. Alternatives include:

1. Issuing a comprehensive and collaborative implementation strategy.
2. Enhancing education and training.
3. Establishing collaborative performance testing/demonstration sites.
4. Establishing systems for ongoing monitoring.

Key lessons learned from this work that inform needs and next steps include:

1. There is a need for an updated comprehensive alternatives assessment on AFFF.
2. Conformance with criteria developed under this project to determine a safer AFFF alternative requires additional product-level testing for specific hazard endpoints.
3. There was resonance in the use of a “fit-for-purpose” performance assessment process for AFFF among stakeholders engaged throughout this project—including representatives of performance standard organizations.
4. In the U.S., the Milspec (MIL-PRF-24385F) is still holding back adoption of alternatives to AFFF, but Congressional deadlines in place for DoD’s efforts to assess alternatives and support research and development of green chemistry alternatives has accelerated the pace of substitution in comparison to other lingering substitution challenges.
5. Additional collaborative and comparative performance testing programs such as those completed at China Lake are needed for the array of users that have lingering questions about the performance of alternatives in specific scenarios.

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.