As we have mentioned previously, certain 'Aqueous Film Forming Foam' (AFFF) product use restrictions have been in play for some time following rulings which have a direct impact on seagoing vessels that stock and use fluorinated foams including AFFF.
If you have more than 50 litres/50kg C8 formulated firefighting foams including AFFF (which is generally fluorinated foams manufactured prior to 2015), then this must be notified to the appropriate government regulator NOW! And by the end of 2022, C8 foams cannot be used unless its 'run-off' can be wholly contained and managed,
Some years ago, global concerns were raised about Perfluorooctanoic acid (PFOA), a chemical closely related to Perfluorooctane sulfonate (PFOS). PFOA can be created by the breakdown of fluorosurfactants with a carbon chain length of C8 or greater. So in simple terms, C8 foams are deemed to be a hazard to the environment.
In the fire fighting foam industry, this means that all AFFF manufacturers were required to reformulate their foam concentrates using C6 fluorosurfactants by the end of 2015. C6 fluorosurfactants can not degrade to PFOA.
From 2020, firefighting foams with a carbon chain length of C8 or greater were prohibited from being used for training and testing purposes
COMMISSION DELEGATED REGULATION (EU) 2020/784 of 8 April 2020 states:
By way of derogation, the use of PFOA, its salts and PFOA-related compounds shall be allowed in fire-fighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems, including both mobile and fixed systems, until 4 July 2025, subject to the following conditions:
(a) fire-fighting foam that contains or may contain PFOA, its salts and/or PFOA-related compounds shall not be used for training;
(b) fire-fighting foam that contains or may contain PFOA, its salts and/or PFOA-related compounds shall not be used for testing unless all releases are contained;
(c) as from 1 January 2023, uses of fire-fighting foam that contains or may contain PFOA, its salts and/or PFOA-related compounds shall only be allowed in sites where all releases can be contained;
(d) fire-fighting foam stockpiles that contain or may contain PFOA, its salts and/or PFOA-related compounds shall be managed
Like most legislative rulings, there is normally a transition period and the end of 2021 is another key milestone in this process whereby if you stock 50 litres or more of C8 AFFF then this must be notified to the appropriate government regulator and, by the end of 2022, C8 AFFF cannot be used unless its 'run-off' can be wholly contained and managed,
For the superyacht and cruise ship industry this is impactful and immediate measures are required to become compliant but there are 'alternatives'.
If you want to know more then email Maritime Aviation:hello@maritimeaviation.com
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