Singapore’s Industry Guideline on the Phase Out of PFAS Firefighting Foams

1. Regulatory Context and Significance

Singapore’s National Environment Agency has issued the Industry Guideline on the Phase Out of PFAS-Containing Firefighting Foams (Revision Date: 12 Nov 2025). This is the country’s first consolidated reference outlining how operators should transition away from PFAS-based foams within a regulated and structured framework. The guideline aligns Singapore with the global withdrawal of PFOS and PFOA exemptions in 2025 and provides interpretive clarity where historically only international practice and scattered OEM recommendations existed.

For high-hazard facilities, the document marks a turning point. Firefighting foam management is no longer an operational preference. It is now a regulated environmental and compliance matter with technical expectations that extend deep into engineering, decontamination, system compatibility, and long-term risk management.

2. Why the Guideline Matters for Operators

The guideline serves three immediate purposes:

1. It sets the baseline requirements for environmental compliance, defining when PFAS-containing foams must be removed, how they must be managed, and how replacement foams should be evaluated.
2. It provides operators with clarity on performance expectations when adopting SFFF. Many plants have waited for national guidance before embarking on transitions, particularly where concerns existed about discharge density, drainage times, structural fire scenarios, and fuel hazards.
3. It confirms that SFFF transitions cannot be approached as simple foam swaps. The guideline formally recognises that engineering analysis, hydraulic verification, and system compatibility assessments are required to ensure that firefighting systems maintain or exceed original design intent.

This consolidation of regulatory, engineering, and operational factors provides a clear roadmap before the 2026 compliance horizon.

3. Technical Expectations Under the Guideline

The guideline reinforces several technical principles that have already been adopted in engineering-led transitions.

3.1 System performance and hydraulic modelling

SFFF concentrates often present higher dynamic viscosities and non-Newtonian behaviour, which influence friction losses, induction efficiency, and system discharge characteristics. The guideline acknowledges that hydraulic modelling must be updated to reflect these properties. This ensures proportioners, bladder tanks, foam pumps, and fixed systems perform within their required operating ranges during design-basis scenarios.

3.2 Compatibility and hardware assessment

Compatibility reviews must confirm that existing hardware can reliably deliver SFFF within tolerance. This includes flow rates, back-pressure limits, concentrate induction parameters, and minimum operating pressures. The guideline supports a full hardware review rather than assuming cross-compatibility with legacy AFFF systems.

3.3 Foam selection and risk alignment

Foam selection is expected to follow a performance-based approach aligned with fuel types, hazard profiles, and application methods. Operators are expected to adopt a performance-based screening rather than choosing products solely on nominal certification labels.

Collectively, these principles confirm that SFFF transition is an engineering exercise requiring validated performance assurance.

4. Decontamination and PFAS Rebound Considerations

One of the most significant contributions of the guideline is its clarity on PFAS decontamination expectations. The document formalises a structured approach that aligns closely with international practice and reflects the realities of older foam systems. It confirms that operators must undertake a validated cleaning process, but it also ensures that expectations remain practical and technically feasible across the range of system types found in Singapore.

At the centre of the framework is the use of controlled hot-water cleaning, supported by repeated flushing cycles that progressively remove PFAS residues from internal surfaces. The guideline recognises that solvents such as methanol and isopropanol may be used under proper safety controls, and that chemical additives or desorption agents can be applied where contamination is persistent or where system geometry makes passive cleaning less effective. Mechanical assistance is acknowledged as a useful supplementary technique, particularly in legacy systems with aged pipework or longstanding deposits.

The guideline’s clear acceptance of ALARP is particularly important for systems where complete PFAS removal cannot be achieved. Many older installations have components that have absorbed PFAS over decades, including elastomers, bladder tanks, proportioning equipment, and long stagnant sections of pipework. The guideline recognises that, even with rigorous cleaning, some residual PFAS may remain. Operators are therefore allowed to demonstrate compliance based on reasonable effort, supported by documentation and sampling, rather than being held to an impractical requirement for absolute removal.

The framework also addresses the PFAS rebound phenomenon. After cleaning, PFAS can reappear in rinse water or solution due to diffusion from internal surfaces. To ensure accurate verification, the guideline introduces a nominal one-month residence period before sampling. This avoids premature testing, provides realistic benchmarks, and aligns with international observations of how PFAS behaves post-cleaning.

Another important clarification is the distinction between components that require PFAS-specific chemical cleaning and those that do not. Full decontamination is required only for equipment that has directly handled concentrate, such as foam tanks, proportioners, and concentrate piping. This reduces unnecessary scope and focuses effort on the parts of a system where PFAS is most persistent.

5. Engineering and Operational Implications for 2026 Compliance

With PFAS foams being phased out, operators face several immediate implications. Engineering and operations teams will need to coordinate closely to maintain fire system performance while meeting environmental and regulatory expectations.

Plants with large or distributed networks such as tank farms, jetties, pump houses, and underground systems will require zone-specific assessment due to varying hydraulic constraints. This shift makes accurate scoping, sequence planning, and documentation essential for both environmental reporting and long-term risk governance.

6. Forward Considerations for Terminals Planning Multi-Year Transitions

Large terminals and high-hazard facilities often require multi-stage transition plans that extend beyond a single maintenance cycle. The guideline supports a phased approach that integrates:

This planning model reduces operational disruption, spreads capital expenditure, and enables technical decisions to be validated progressively rather than all at once.

7. Closing Thoughts

Singapore’s new Industry Guideline provides long-awaited clarity on the technical and environmental expectations for phasing out PFAS-based firefighting foams. Its alignment with global regulatory shifts, combined with explicit guidance on decontamination and performance engineering, sets a clear direction for operators preparing for the 2026 deadline.

For high-hazard facilities, the transition is now an engineering-led compliance exercise that requires validated modelling, system compatibility reviews, structured cleaning plans, and performance assurance. The guideline confirms that these steps are no longer optional, and they collectively form the foundation of a responsible and technically sound SFFF transition.