INFORMATION LETTER DATED 21.02.2022
Current ban on harmful PFC fire extinguishing foams in Europe
The maximum permitted limit value for PFOS and its salts is less than or equal to 10000 µg/kg in accordance with Regulation EU/2019/1021. For PFOA and its salts, a limit value of 25 µg/kg has applied since July 4, 2020 in accordance with Regulation EU/2017/1000 and EU/2020/784. Foam extinguishing agent concentrates that exceed the aforementioned limit values for PFOA and its salts may only be used for fighting liquid fires and only until July 4, 2025 at the latest.
From January 1, 2023, this will only apply if all releases can be contained. For the sum of C9-C14 perfluorocarboxylic acids and their salts, a limit value of 25 µg/kg has applied since August 4, 2021 in accordance with Regulation EU/2021/1297. Foam extinguishing agent concentrates that exceed the aforementioned limit value for the sum of C9-C14 perfluorocarboxylic acids and their salts may only be used for fighting liquid fires and only until July 4, 2025 at the latest if all releases can be contained.
Further information can be found in our Technical Information TI-064.
PFOA is toxic to reproduction and the liver!
History:
2019 – ban / limit value reduction for PFOS only
2019/2020 – Supplementary ban for PFOA
08/2021 – Supplementary ban for PFPA C9-C14 perfluorocarboxylic acids
Press and technical articles:
Environmental pollution Extinguishing foam with toxic PFCs contaminates soil and groundwater in Manching. It’s all about perfluorinated and polyfluorinated chemicals – PFCs for short. Scientists cannot rule out the possibility that these substances are harmful to humans. PFCs can be found in extinguishing agents.
PFC stands for per- and polyfluorinated chemicals. PFC substances are highly water-repellent and can be found in rainproof clothing and Teflon pans. The chemicals are suspected of being harmful to health. Large-scale studies are currently underway. Scientists such as Jörg Drewes, head of the Chair of Urban Water Management at the Technical University of Munich, are already warning against these substances: “Medical and clinical trials have shown that these substances are also carcinogenic. It is often not the case that we have a clear threshold concentration, but rather the smallest concentrations are theoretically capable of causing cancer.”
PFC exposure in the Bundeswehr:
Fire departments around the world use PFC-containing foam extinguishing agents to fight certain fires, especially severe fires involving petrol or kerosene that pose a high risk to people. These extinguishing agents are very effective in fighting fires involving burning liquids or melting solids.
PFC-containing extinguishing foam is also used by the German Armed Forces. Since 2007, the use of the PFC substance “perfluorooctane sulfonic acid (PFOS)” has been regulated by an amendment to the Chemicals Prohibition Ordinance and the Hazardous Substances Ordinance. The Bundeswehr naturally takes this into account and only uses substances and products that are defined as “PFOS-free” within the framework of the legal provisions.
Is the use of the extinguishing agents used by the Bundeswehr prohibited?
No! The Bundeswehr only uses extinguishing agents that meet the legal requirements. EU Directive 757/2010/EU sets the maximum concentration for PFOS in extinguishing foams at 0.001 percent by mass. This concentration is considered “PFOS-free” according to the EU directive. The ban therefore only applies to extinguishing foams that exceed this concentration. There is currently no ban on other PFC substances.
Problem of decontamination:
Foam concentrate cannot simply be replaced by a trivial exchange, as experience has shown that residual segments of PFC will migrate into the new foam concentrate. The result would be a complete recontamination of the current “PFC-poor/free” foam concentrate. Refilling the tank using old working materials can also lead to recontamination of the foam concentrate. 25µg/kg is a very small measurement and can only be determined and quantified in a laboratory.
If old foam concentrate needs to be replaced, please note the following:
- PFC analysis of the foam concentrate to be replaced provides information on the further process sequence. During the regular/routine foam quality inspection, a PFC analysis must be carried out or ordered separately. If this test is not carried out, a contamination must be assumed in accordance with the “principle of concern”.
- in the event of a PFC positive above the limit value, the entire system must be decontaminated “in accordance with laboratory requirements”. If you have any questions about the laboratory report, our specialist company will help you in any case.
- check whether system components need to be replaced due to migration.
- experience has shown that simple replacement is not feasible for bladder tanks, as the old bladders are usually not functional and have corroded and heavily contaminated the inside of the tank. Further analysis and assessment required.
- PFC contamination is also possible through contaminated work equipment. Only professional execution by a specialist company will ensure decontamination.
- after decontamination and recommissioning of the plant, a comprehensive decontamination and analysis report must be handed over to the plant operator, which will safeguard him in the event of subsequent UBA inquiries in a separate case. The obligation to provide evidence to the Federal Environment Agency is also regulated by law.
For the system operator / owner and distributor, it counts if they knowingly violate environmental requirements:
Environmental offenses are particularly serious violations of environmental law. The legislator punishes these as a last resort (so-called ultima ratio) with fines or imprisonment. In doing so, the legislator has expressed that society particularly disapproves of these serious violations of environmental law. At the same time, the legislator has used these regulations to implement European requirements for effective environmental protection (EU Directive on Environmental Criminal Law, 2008/99/EC).
Particularly serious offenses, e.g. those that endanger the public water supply (Section 330 of the German Criminal Code), are punishable by a prison sentence of up to ten or fifteen years.
Further restrictions
EU-wide restrictions on the production and use of C9-C14 PFCAs and PFHxS are currently being prepared by the legislator.
Our references for PFC decontamination 2019/2022:
We will be happy to send you an excerpt from an extensive reference list on request.
We are happy to offer our customers competent support for technical processing. Technical advice and instructions / information briefings are also part of our offer.
