October 9, 2025 On October 1, 2024

PFOA / PFAS Firefighting Foams — Do I Need to Take Action?

Updated 2025 Guidance

PFOA / PFAS in Fire-Fighting Foams — Do I Need to Take Action?

Identify your foam, test correctly, interpret thresholds, and plan business continuity under EPMA/NEA.

PFAS have long been used in AFFF for Class B risks. They persist in the environment and may impact soil and groundwater. This guide explains how to check your site, verify foam composition, and take appropriate actions.

PFOA + salts

≤ 25 ppb

PFOS

≤ 10 ppm

PFHxS

≤ 100 ppb

Thresholds shown for quick reference. Always confirm the latest regulatory guidance and test methods.

01 Inspect Your Site

Look for any foam storage or discharge equipment: storage tanks, IBC totes, drums or pails; foam chambers, monitors, hose reels; portable/wheeled extinguishers; mobile units or tenders.

No foam on site → No further action required

02 Identify the Foam Type

Ask your supplier whether your foam is long-chain fluorinated (LC-PFAS, legacy) or modern C6. If unsure, review manufacturing date and origin; PFAS foam produced before 1-Jan-2016 should be assumed to contain C8 fluorinated materials. Share the SDS with your consultant for confirmation.

LC-PFAS identified → Commence transition planning

03 Arrange Laboratory Testing

Test even if the SDS or vendor claims “no PFOA/PFOS/PFHxS.” Such statements usually refer to “no intentionally added” substances; trace residuals or degradation by-products may still exist. Residuals from past products can remain in systems not thoroughly decontaminated during change-outs.

Targets & action levels

PFOA > 25 ppb → non-compliant
PFOS > 10 ppm → non-compliant
PFHxS > 100 ppb → non-compliant

04 Select an Accredited Laboratory

Use an accredited lab following the latest international PFAS guidance. The Stockholm Convention on POPs lists numerous related compounds under PFOA and its salts; the target list evolves, so periodic re-testing may be required to maintain compliance.

05 Interpret the Results

Compliant

PFOA < 25 ppb, PFOS < 10 ppm, PFHxS < 100 ppb → No further action required. Proceed to stock/continuity checks.

Non-compliant

Any exceedance → Commence transition planning. Consider system decontamination, product replacement, and re-testing.

06 Risk & Business Continuity

Ensure availability of AFFF/AR-AFFF for system reinstatement after any discharge.
Obtain a Manufacturer’s Letter of Continuation confirming supply support horizon.
Adopt a risk-assessment-based approach for continuity planning.

Major manufacturers of film forming foam concentrates, including Angus, National Foam, Ansul, Chemguard, Sabo, Skum and Williams, have suspended manufacturing of fluorine-containing foams in 2024.