Dear CS Listserv Subscriber:
The attached letter and fact sheet is to alert government officials and fire, health, safety, and environmental professionals to the health risks posed by certain aqueous film forming foam (AFFF) fire suppressants manufactured prior to 2002 that contain per- and polyfluoroalkyl substances (PFAS) and to recommend you take action to remove these products from your fire suppression inventory, if necessary. These PFAS and precursor compounds include perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), which are suspected to adversely affect human health and are both difficult and costly to clean up in the environment after use.
The Department of Environmental Conservation (DEC) has established cleanup levels in regulation in 18 AAC 75 for PFOS and PFOA in contaminated soil and groundwater. Given that PFOS and PFOA-containing products are considered hazardous substances, DEC requires the release of these products, in any amount, to be reported immediately to the State.
In the last several years, DEC has identified a growing number of contaminated sites across the state where the use of certain formulas of AFFF during fire suppression and training has resulted in the release of PFAS, including PFOS and PFOA, into the groundwater. At some of these sites, the PFAS contamination has impacted community water supplies. In addition, workers who use AFFF are often exposed directly to these chemicals during fire suppression activities. While the science surrounding these compounds is still evolving, DEC believes it is in the public’s best interest to share with facility and vessel operators as much information as possible about these risks so former and current users of PFAS-based AFFF can take appropriate action to reduce risks to human health and the environment. For more information about the health risks, chemical structure, use and manufacturing history of specific formulas of AFFF, or how to dispose of products you may have in your inventory, please refer to the attached fact sheet.
DEC recommends that if you use AFFF in your operations or store these products for use in fire-suppression, you should review your inventory for AFFF products that were manufactured prior to 2002, as these stocks may likely contain PFAS. If you have such products, we strongly encourage you to remove them from use and replace them with more recently manufactured AFFF. AFFF that contains PFAS should be returned directly to the manufacturer or shipped out of state for disposal by a certified hazardous waste disposal company.
· For more information on disposal of PFAS-based AFFF, please contact the Statewide Hazardous Material Team Coordinator at (907) 269-4198.
· For questions about whether a release at your facility or a site where AFFF was used may have resulted in contaminated soil or groundwater, please contact the DEC Contaminated Sites Program at (907) 465-5390.
Thank you for your attention and assistance in helping protect Alaskans’ public health and environment.
Unit Manager for Technical Services, Policy & Regulations
ADEC Contaminated Sites Program – Juneau, Alaska
Division of Spill Prevention and Response
DEC Division of Spill Prevention and Response Contaminated Sites Program
AFFF Advisory Letter And Fact Sheet