Planning for a fluorine free future: Transitioning away from PFAS firefighting foams

For decades, aqueous film forming foams (AFFFs), which are based on per‑ and polyfluoroalkyl substances (PFAS), have been a cornerstone of fire protection strategies, particularly in high‑risk environments such as aviation, petrochemical processing, waste management, and industrial storage. Their effectiveness against flammable liquid fires is well established. However, the same fluorinated compounds that made AFFFs so successful are now at the centre of growing environmental, health, and regulatory concern.

PFAS, often referred to as ‘forever chemicals’, are extremely persistent in the environment. Once released, they do not readily break down, accumulating in soil, groundwater, and living organisms. An increasing body of scientific evidence has linked PFAS exposure to adverse health effects, including impacts on the immune system, hormone disruption, and certain cancers. As a result, regulators across the UK and Europe are moving decisively to restrict (and ultimately eliminate) PFAS‑containing firefighting foams.

The withdrawal of legacy PFAS‑based AFFFs is no longer a theoretical future issue, it is already underway. In the UK, the use of older foams containing substances such as PFOS and PFOA is now prohibited. In addition, consultation is progressing on further restrictions that will significantly limit the continued use of all PFAS‑based foams. In parallel, the European Union has set out a clear pathway towards the complete removal of PFAS foams, with defined transition periods leading to a fluorine‑free end state.

Environmental permitting for AFFFs

What is increasingly understood, but not always fully appreciated, is how closely this issue intersects with the environmental permitting regime. Many industrial and waste sites operate under environmental permits that strictly control discharges to land and water, require pollution prevention measures, and place a duty on operators to use best available techniques. The uncontrolled release of PFAS‑containing foam during a fire, system test, or accidental discharge has the potential to contaminate surface water, groundwater, and soils, triggering permit non‑compliance, enforcement action and long‑term remediation obligations.

In this context, reliance on PFAS‑based firefighting foams is no longer just a fire safety decision; it is an environmental risk management issue. Operators may find themselves exposed to regulatory scrutiny not because a fire occurred, but because the chosen method of fire suppression resulted in environmental harm that could have been avoided.

Preparing for a fluorine-free future

Many asset owners and duty holders remain underprepared for this shift away from AFFFs in the UK and Europe, with a common misconception being that the transition to other products can be addressed quickly once final deadlines for AFFF phase out have been reached. In reality, moving away from fluorinated foams is rarely as simple as a like‑for‑like product swap:

• Fluorine‑free foams, often referred to as F3, behave differently in terms of viscosity, drainage time, and application rates. Fixed systems designed around AFFF performance may therefore require modification, recalibration or, in some cases, more fundamental redesign to maintain equivalent levels of fire protection.
• Existing systems must be thoroughly cleaned before fluorine‑free agents can be introduced, to prevent cross‑contamination, because even trace residues of legacy foam can result in the replacement agent failing to meet compliance requirements.
• Stocks of legacy foams require careful handling and disposal through approved routes, often at significant cost and with limited specialist capacity.

Consequently, if left unplanned, these challenges can lead to unanticipated downtime, budget overruns, and increased operational risk.

Importantly, this transition is not solely a compliance exercise. It represents a broader shift in how organisations demonstrate environmental responsibility and risk stewardship. PFAS contamination incidents have already resulted in substantial remediation costs, reputational damage and long‑term liabilities for landowners and operators. Proactively removing a known source of forever chemicals is increasingly viewed by regulators and the public as a marker of basic good governance rather than optional best practice. Insurers, too, are taking a more cautious stance, with some refusing to cover PFAS‑related liabilities where the perceived risk is too great – potentially leaving operators exposed to unlimited future costs.

The move towards a fluorine‑free future is inevitable. The question facing organisations today is not whether they will need to transition away from PFAS‑containing AFFFs, but whether they will do so strategically or reactively. Those who act now will be best placed to manage risk, control costs, and maintain robust fire protection.

How SLR can help

SLR can assist operators by, for example:

• Auditing estate portfolios and existing assets
• Reviewing AFFF-related environmental permit implications
• Advising on the management of legacy foams and extinguishers
• Assisting in embedding PFAS withdrawal into long‑term planning