Once found in everything from water-repellent clothing and nonstick cooking surfaces to aqueous film-forming foam (AFFF), PFAS are a group of synthetic chemicals that have come under regulatory scrutiny due to the potential risks they pose to human health and the environment. Since early in the century, the U.S. Environmental Protection Agency (EPA) has worked with various industries to phase out certain PFAS from commercial production.
Of the more than 1,000 PFAS inventoried by the EPA, about half are still commercially available, including those found in AFFF. If not properly managed, airports face the risk of PFAS being released into the environment via stormwater, groundwater, surface water and soil with each use of these foams.
Several states have passed regulations to address PFAS impacts to the environment — past and present. Recent examples include California, Massachusetts, Michigan, Minnesota, New Jersey, New York, Vermont and Wisconsin. The EPA, meanwhile, has moved to have PFAS listed as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). As regulated compounds, PFAS would be governed by the strict handling and disposal guidelines prescribed in CERCLA and the Resource Conservation Recovery Act. In addition, potentially responsible parties of Superfund sites would be required to address PFAS contamination as part of remediation efforts.
The Federal Aviation Administration (FAA) has also entered the conversation. The FAA previously required airport operators to utilize PFAS-containing AFFF during mandated tests of firefighting equipment and when responding to fires. However, in January 2019, the FAA issued a National Part 139 CertAlert recommending several alternative Aircraft Rescue Firefighting (ARFF) testing systems. During the prior year, the FAA Tech Center completed research on three types of testing equipment that do not dispense foam. The FAA’s intention with these systems is to minimize the release of PFAS to the environment and satisfy Part 139 testing requirements.
To reduce airport reliance on PFAS for ARFF, efforts are also underway to develop and test PFAS-free AFFFs as replacements for PFAS-containing products. While the FAA is working to identify a reliable PFAS-free AFFF and plans to remove its mandate requiring the use of PFAS-containing AFFFs by October 4, 2021, airport operators will be expected to depend on PFAS-containing foams for at least the foreseeable future.