Public comments on IChEMS proposed standards

[redacted]

Consultation submission to Department of Climate Change, Energy
the Environment and Water (DCCEEW): IchEMS Consultation PFAS
Scheduling Decisions.

Proposed Scheduling of PFOS, PFOA and PFHxS

31st August 2023.

[redacted]
Sent by e-mail to: ichems.enquiry@dcceew.gov.au, and via on-line submission portal https://consult.dcceew.gov.au/ichems-s17-proposed-decisions

Note: Reference documents are listed in numerical order at the end of this submission. Numbers are shown in the text relating to these specific reference documents, highlighted in red superscript, for easier visibility.

Summary
Firstly, thank you for the opportunity to provide constructive comment as part of this
Consultation. [redacted] interest and expertise relates to firefighting foams and their delivery systems. We therefore endorse these proposed scheduling decisions for PFOS, PFOA and
PFHxS to be prohibited from use under Schedule 7, bringing Australia in line with EU and bringing long awaited ratification of these PFAS, as listed POPs under the Stockholm Convention.

It does however raise the question of what scheduling decisions will be made concerning other groups of more benign PFAS used in firefighting foams? C6-PFAS containing foams are widely recognised as essential use when fighting major flammable liquid fires. The European Chemicals
Agency (ECHA) Socio-Economic Assessment Committee’s March 2023 draft opinion on the restriction of PFAS in Firefighting Foams, highlighted concerns (Section 1.2, p9-10)60 that
“Regarding the transition periods proposed by the dossier submitter, SEAC considers that some

Submission to CASA – High temperature Foam verification at Australian Airports 1
transition periods may need to be extended, however, SEAC lacks detailed enough information to recommend a specific length.”

While also recognizing (p49)60 “However, as explained in Table 9, there is a concern that the transition times proposed by the Dossier Submitter might not be sufficient to ensure the development, full testing and adoption of alternatives suitable for the most challenging types of fires. Given the potential very high impacts of even a single catastrophic fire on human health and the environment, the proportionality of the proposal is uncertain if risks of such catastrophic fires are not kept as low as they are currently. SEAC recommends in this context to adopt a no- regret strategy; that is, a restriction option that remains justifiable whether catastrophic fires take place or not.”

These concerns are supported by extensive fire testing and research provided in Appendix A, confirming that non-fluorinated alternative foams do not provide equivalency of fire performance and functionality when compared to high purity short-chain ≤C6-PFAS based foams. Particularly under high ambient temperature conditions increasingly being experienced in Australia and internationally. January 2023 saw the New York Times reporting “The last 8 years were the hottest on record”, with 2023 potentially hotter still. Unprecedented temperature records are being broken across the northern hemisphere during 2023, like 2022. These exceed 40oC, including at
London Heathrow airport54, and Paris; Rome; Madrid; Athens; Tehran; Delhi; Bangkok; Beijing;
Dallas72 etc.

Growing research also indicates less severe human health impacts of PFAS foams, also provided in
Appendix B, based on firefighter studies and those of PFAS impacted communities following prolonged AFFF use at Defence bases nearby, and reducing trends of PFAS blood serum levels across all age groups and demographics in the general US population.

Other long-chain ≥C8-PFAS which could break down to PFOS, PFOA or PFHxS, should also be restricted from use and probably prohibited under Schedule 7, as those breaking down to
PFOS/PFHxS have not been manufactured since 2003 in Australia. C8-Fluorotelomer based firefighting foams also ceased manufacture (outside China and perhaps Russia) by end 2015, in accordance with US EPA PFOA Stewardship program70 and EU Regulation 2017/100071 which permitted residual traces of PFOA up to 25ppb of PFOA, its salts, and 1,000ppb of PFOA related substances (including pre-cursors) in high purity C6-PFAS containing foams.

The evidence presented within this submission should encourage DCCEEW to ensure proportionate Scheduling of these essential use C6-foams for emergency use in major flammable liquid fires. From the scheduling information currently available in the IchEMS 2021 Road Map, these would be expected to be categorised under Schedule 4 or perhaps 5. An extensive
Reference list is also provided to facilitate verification of this information.

Yours sincerely,

Submission to CASA – High temperature Foam verification at Australian Airports 2
[redacted]
[redacted]

APPENDIX A: Fire testing and scientific research evidence.
Note: Reference documents are listed in numerical order at the end of this submission. Numbers are shown in the text relating to these specific reference documents, highlighted in red superscript, for easier visibility.

1. Australian Bureau of Meteorology Airport temperatures reported 2018-20221.
This shows a summary of temperature data recorded for 21 of Australia’s 27 airports
with ARFF Services.

2. Wang, Peng et al, 2023 – Decreased Aircraft Take-off Performance under Global
Warming8 confirms that:
• “It is urgent and crucial to understand the effects of increasing temperature on the
complicated and comprehensive performances of aircraft. As air warms, it becomes
less dense. Low-density air conditions further lead to reduced lifts for aircrafts, which
significantly influences the maximum takeoff weight (MTOW) of an aircraft.”
• “Coffel and Horton [17] found that the number of summer days necessitating weight
restriction had increased in the United States since 1980 along with the observed
increase in surface temperature. “

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• “The warming air leads to the MTOW [Maximum Take-Off Weight] reducing and
takeoff distance increasing. Taking the Boeing 737–800 aircraft as an illustration, the
number of weight-restriction days increases significantly across the airports [as
temperature projections increase with global warming], which can influence airlines’
economic benefit and flight operations in the future. “

• “It is also found that the takeoff distance does not change linearly with temperature
but shows a stronger increase with higher temperature.”

3. US Naval Research Laboratory - Conroy & Ananth (NRL) 2015 – Fuel Surface
Cooling by Aqueous Foam: A Pool fire Suppression Mechanism9. Investigated
temperature differentials which were found to become critical. It used 1.5cm foam in
contact with 1.3cm heptane both at 20°C before fire (with pre-burn: 30s). It found:
• “In this work, we investigate fuel surface cooling by the foam and the resulting reduction
in fuel vapor pressure, which depends exponentially on the surface temperature.”
• Rapid cooling of the boiling heptane at 98.6°C to 54°C by foam at room temperature 20°C:
“The temperature gradient is initially very large at the interface, transitioning from the
boiling temperature of heptane (98.6oC) [8] to room temperature (20oC) in the foam. As
a result of the large temperature gradient between the foam and fuel layers, heat
conducts very quickly from the fuel to the foam, which reduces the surface temperature
of the fuel.”
• “The foam cools the hot fuel surface, reducing fuel vapor pressure and mass transport
into the fire. Based on this principle, we propose a new fire-suppression mechanism that
acts in conjunction with the well-known mechanism wherein the foam forms a physical
barrier to the transport of vapor from the fuel surface into the fire.”
• This rapid cooling drastically affects the fuel vapor pressure (by >70%): “The model shows
significant surface cooling and the associated fuel vapor suppression during the first few
seconds following instantaneous and uniform application of a foam layer onto heptane
pool following a pre-burn of 30s.”
• “With time, the heat conducted from the fuel surface raises the temperature of the adjacent
foam, and the temperature gradient reduces (reducing the magnitude of heat conduction).”
• “Figure 8 shows that the decrease in surface temperature due to both direct and indirect
cooling is over 40oC after 1 s, whereas the temperature decreases by only a few oC with
indirect cooling alone. These results support that direct cooling drives the rapid,
significant decrease in fuel surface temperature and that indirect cooling is relatively
unimportant.”
• Proposed to be a new contributing mechanism for fire extinguishment vs. conventional
understanding of foam as a physical vapor barrier.
• Higher foam solution temperatures (in hot summers) would substantially reduce this
discontinuity effect, reducing cooling, thereby making the fire much harder and slower to
control and extinguish.

4. US Naval Research – Conroy, Fleming & Ananth (NRL) 2017 - Surface Cooling of a
Pool Fire by Aqueous Foams10

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This follow-up study to the 2015 paper, validated earlier conclusions with lab fire tests. Fuel
cooling model calculations for interfacial temperature were validated against experimental data
using:

• Lab modeling test of 28ft2-pool US Mil-spec test:
• Pan size: 19cm diameter
• Fuel: Heptane
• Fuel depth: 1.0cm vs 1.5cm (28ft2 Mil-spec)
• Pre-burn time: 60sec vs 10sec (Mil-spec)
• Samples: RF6 (Solberg) & Buckeye 3% Mil-spec AFFF

• Foam solution/Fuel temperature: room temperature (20oC)
• 2.0 cm foam thickness/ 1cm fuel depth (vs. previous model: 1.5cm foam thickness/1.3cm fuel
depth).

Tests concluded that:
• The measurements show rapid (<10s) and significant (25°C) cooling of the fuel close to the
foam-fuel interface in good agreement with the model predictions.
• Right after pre-burn (60s) and immediately after foam application, the fuel temperature at
the foam-fuel interface decreases rapidly: “Measurements show that the fuel temperature
near the foam-fuel interface (~1mm deep) decreases from about 85°C to less than 60°C in
less than 10s.”
• “Cooling of liquid fuel surface has a strong effect on the fuel vapor pressure which drives
the evaporation of flammable gas away from the liquid fuel surface.” (<10sec, >70%
reduction).
• “We propose that the very fast and significant vapor pressure reduction caused by
cooling with foam could contribute strongly to suppression of pool fires by rapidly
decreasing the fuel evaporation rate. The rapid effect of surface cooling could play an
important role in knockdown of the flames in the initial stages of fighting a pool fire.
However, the surface cooling mechanism alone will not completely extinguish a flame
because it will not suppress evaporation enough to prevent the formation of a combustible
fuel-air mixture. Flame extinction is impacted by other mechanisms, such as fuel transport
through the foam, which would be reduced by surface cooling of the fuel. Reduced fuel
transport through foam tends to enhance flame extinction.”
• “More importantly, the measurements and predictions unanimously support the idea
that rapid, significant interfacial cooling occurs when a room-temperature foam is
applied to a hot heptane surface, supporting our claim that surface cooling could have a
rapid, significant effect on pool-fire suppression.”
• “This rapid cooling of the fuel surface can result in rapid reduction in fuel vapor pressure.
Therefore, cooling the fuel surface with foam could quickly reduce the fire size and the
heat release rate because of the reduced combustion rate, which depends directly on the
fuel vapor concentration.” Strongly suggesting foam temperature is important in
maximising this effect.
• “During the preburn time, the fuel receives heat from the flame. The thickness of the
heated region beneath the fuel surface (i.e., thermal boundary layer) therefore increases
with preburn time. …for RF6 foam [F3] applied to heptane pool fires, that increasing the

Submission to CASA – High temperature Foam verification at Australian Airports 5
preburn time can also increase the time and amount of foam required to extinguish a
pool fire.”
• “Note that the MILSPEC tests are conducted with a preburn time of 10 s; our measurements
suggest that the foam could have a slightly greater cooling effect in these tests because
of the relatively short preburn time.”

This research strongly suggests that cool foam temperature has an important effect in cooling
the fuel surface and extinguishing the fire. Therefore hot foam solutions would not have the
same beneficial effect making it harder and slower to extinguish. It also suggests fires with
longer pre-burns (or even burnback re-ignitions) are harder to extinguish, requiring more foam
solution and taking longer to extinguish.

5. US NRL 2017 – “Influence of Fuel on Foam Degradation for F3 and AFFF”11 found:
• “Water evaporation from the foam bubbles can also contribute to degradation. …heat from a fire
can dramatically increase the rate of foam degradation through water evaporation.”
• “For all experiments F3 degraded much faster than AFFF …Our results showed RF6 degraded
faster than AFFF (by factor of 3 at room temperature [20oC] and 12 at elevated temperatures
over fuel [50oC]), which may contribute to differences in their firefighting performance.”
• “As the fuel temperature is raised, there is a higher concentration of fuel vapors beneath the
foam than at lower temperatures. This increased concentration at the foam interface can
increase the amount of fuel transport through the foam, increasing the rate of foam
degradation.…For all experiments F3 degraded much faster than AFFF.
• “The fuel temperature effect is by far the largest compared to the effect of different fuels and
surfactant formulations (including the additives). The effect of surfactant formulation is a close
second relative to the temperature effect;” Results explained by specific fuel repelling AFFF
additives withstanding such pre-mature breakdown, maintaining rapid fire control under hot
conditions.
• “Our findings show faster fuel-induced degradation of RF6 [F3] foam may contribute
significantly to its inferior fire suppression performance relative to AFFF foam.”

6. FAA (Sheffey, Darwin & Hunt) 201212 - Research calculating firefighting agent
quantities for aircraft crash fires, found aircraft composite materials behave differently.
It cautioned:
• “FAA research indicates that when an aircraft is involved in a fuel spill fire, the
aluminum skin will burn through in about 1 minute. If the fuselage is intact, the sidewall
insulation will maintain a survivable temperature inside the cabin until the windows
melt in approximately 3 minutes. At that time, the cabin temperature rapidly increases
beyond a survivable temperature of 400°F[ 204oC].”
• ”Therefore, ARFF personnel and equipment must reach the scene in 2 minutes to meet
the anticipated burnthrough scenario.”
• There is also potential for re-ignition of a fuel fire from smoldering fuselage
composites.”
• It referenced US Military graphite/epoxy/carbon fiber composite testing, finding “this
composite would self-sustain combustion in as little as 2.5 minutes of exposure to an
external pool-type fire. …The pool fire was easily extinguished in all tests. However,
extinguishment of the composite combustion was not as easy.”

Submission to CASA – High temperature Foam verification at Australian Airports 6
• “The surface flames were readily extinguished, but smoldering composite combustion
was already established.”
• “PKP [Dry Chemical] was effective at extinguishing the surface flames on the composite
panels, but it did not extinguish the smoldering composite combustion.”
• “To extinguish …fire fighters applied a continuous stream of AFFF directly on the
composite material. After applying AFFF for 3 minutes or more, the smoldering
composite combustion was extinguished.” Such re-ignition sources further expose F3
vulnerabilities, without fuel repelling and vapour sealing additives.
• It was “noted that quick response and quick knockdown of the fire by airport fire
equipment offer the best chance of passenger survivability in an aircraft crash situation.
• They recommended a maximum response time of 3 minutes, recognising that “this time
period is considered by most authorities to be longer than can actually be tolerated to
assure survivability of all passengers.” They asserted that the effectiveness of an airport
crash fire/rescue service diminishes rapidly with response times to the scene of a crash
in excess of 2 minutes, based on their thermal analysis as described in section 3.2.2.
They indicated that a desirable response time would be 90 seconds (0-second response
time would be the goal, but it is obviously not practical), with a 2-minute response as
optimum. Even these response times, they noted, will not be adequate for major crash
fires, in which fuselage openings are directly exposed to fire or in which the cabin
interior is involved.”
• ” The new FAA 4-minute burn-through criteria dramatically reduced the chances of
interior ignition for the intact aircraft crash scenario.” This 4-minute burn-through
scenario presumably explains the extended 3 min response time in NFPA 403:2018 from
the previous 2 minutes, but still seems to assume “, the extinguishing agent must be
applied to control a fire in one minute or less.” This may not be achievable using modern
F3s, achieving ICAO Level B and C fire test extinguishments within 2 minutes at 15oC,
without taking into account the likely reduced fire control capabilities, when operating
under hot summer conditions, likely at or above the flashpoint of JetA1. Are we ignoring
realistic credible events during summer?
• “It was concluded that fast response by the fire fighters reduced the chance that
smoldering fire will be established. Since fire fighters may have to work in close to the
aircraft to control the composite fire, they must be aware of potential re-ignition of fuel
under or around the aircraft.”

7. NFPA 403:2018 Standard (current) for Aircraft Rescue and Firefighting (ARFF)
Services at Airports5 Annex B.6 explains…
• “There has been limited full-scale testing of ICAO C foams, but tests to date have
reflected extinguishments on Jet A within 1 minute at ICAO Application rates of 0.992
gpm/ft2 (3.75L/min/m2). The 0.13gpm/ft2 (5.5L/min/m2) application rate requirement
for AFFF meeting MilSpec in NFPA 403 is 40% higher.”
• This raises a BIG question: …Are alternative ICAO Level B/C F3s still effective at this low
40% safety factor operationally? when considerably less than existing double or triple
safety factors currently used by ICAO Level C/US MilSpec approved C6-AFFFs?
• Annex B.6 continues “Airports adopting ICAO foam concentrates should evaluate
equipment requirements any time a switch to a new manufacturer of foam
concentrates is considered.

Submission to CASA – High temperature Foam verification at Australian Airports 7
• Therefore, starting with 2018 edition of NFPA 403, the following application rates by
test standard are used:

(1) Mil-F 24385 and ICAO Level C = 0.13gpm/ft2 or 5.5L/min/m2
(2) ICAO Level B = 0.18gpm/ft2 or 7.5L/min/m2
(3) ICAO Level A = 0.20gpm/ft2 or 8.2L/min/m2”

This is of particular concern to Regulators, Fire testing Standards agencies and industrial foam
users, when extensive comparative fire testing confirms F3s deliver inferior fire performance to
C6-AFFFs and may require typically 2-3times higher application rates to even extinguish test fires
on volatile fuels like gasoline and Jet A1. Safety factors should therefore be significantly higher
than just 40%, at least double confirming operational use at 7.5L/min/m2 or above potentially for
ICAO Level B approved F3s (not 5.5L/min/m2 as currently)?

It begs the question: Should UL Safety factors be increased from frequently used 1.6 factors to
2.0 factors of safety? If not, why not? - particularly when SFFFs are shown extensively to require
higher application rates on volatile fuels and more demanding operational situations?

Is it SAFE for US and European airports to be using ICAO Level B F3s at just 5.5L/min/m2
application rate, when the current NFPA 403 standard is recommending ALL ICAO Level B
approved foam be used operationally at 7.5L/min/m2 to avoid increasing risks to life safety?
Who is liable should a tragedy happen?

8. Chen et al, 2011 – Initial fuel temperature effects on burning rate of pool fires13
confirmed:
• “The burning rate during the steady burning stage was observed to be relatively independent of
the initial fuel temperature. In contrast, the burning rate of the bulk boiling burning stage
increases with increased initial fuel temperature.”
• “It was also observed that increased initial fuel temperature decreases the duration of steady
burning stage. When the initial temperature approaches the boiling point, the steady burning
stage nearly disappears and the burning rate moves directly from the initial development stage
to the transition stage.”
• “The fuel surface temperature increases to its boiling point at the steady burning stage, shortly
after ignition, and the bulk liquid reaches boiling temperature at the bulk boiling burning stage.”

9. Zhou et al, 2022 – Thermal stability and insulation characteristics of three-phase
firefighting foam exposed to radiant heating14 found:
• “The thermal stability, the volume expansion, and the temperature profiles inside the foam layer
exposed to the high-temperature environment were studied.”
• “The results indicate that the high ambient temperature benefits the foaming but reduces the
foam stability. The foam layer exposed to continuous radiant heating presents three successive
stages, i.e. the initial stage, the balanced stage, and the collapse stage due to distinct heat
transfer characteristics in the depth direction.”
• “It is found that the insulation performance of foam can be enhanced with higher particle
concentration, especially hydrophobic particles. High foam expansion ratio leads to better foam
stability but worse thermal insulation. The life of foam decreases with the radiation heat flux.”

10. Xu et al, 2020 – Fire extinguishing performance and mechanism of AFFF in diesel
pool fire15, confirmed:

Submission to CASA – High temperature Foam verification at Australian Airports 8
• “Infrared thermal imaging analysis indicates that the main fire-extinguishing mechanism of
AFFF is mainly ascribed to the superior cooling, covering and suffocating effects of foam against
the transfer of heat and oxygen, thus effectively preventing the underlying fuel from further
combustion.”
• “When the fluorocarbon surfactant is combined with the hydrocarbon surfactant, the
emulsification ability and spread rate of AFFF in the oil are promoted that the foam solution from
the process of drain and rupture can spread rapidly on the surface of the liquid hydrocarbon fuel.”
• “In addition, an aqueous-quality film is formed between the foam and the fuel to make AFFF
have a double fire-extinguishing effect of foam layer and aqueous film, thereby improving the
fire-extinguishing performance of AFFF.”
• “As the layer of foam accumulates, the foam gradually spreads over the oil surface and forms an
effective covering layer, which further reduces the burning area and the flame temperature. With
the further spreading of foam, the temperature of oil covering by foam is below the diesel
ignition point of 220oC, resulting in the extinguishing of diesel pool fire. During the fire-
extinguishing process, the foam cover layer can effectively terminate the combustion and
prevent the occurrence of re-ignition. And, the combustion is further weakened and
extinguished until the entire oil pan is covered by foam layer.
• “Based on the above analysis, it can be seen that the AFFF mainly reduces the evaporation rate of
the flammable liquid and isolates the thermal radiation of flame on the combustion surface
through covering and cooling effects, thus achieving an effective fire-extinguishing
performance.”
• Concluding” (3) The fire-extinguishing mechanism of AFFF is manly ascribed to the superior
cooling, covering and suffocating effects. AFFF can quickly form a coverage on the surface of
flammable liquid, which isolates the flame from heat feedback and suppresses the generation of
flammable vapor.”
• “The evaporation or drainage of AFFF causes cooling effect on the surface of combustion zone;
meanwhile, the vaporized water can dilute the concentration of oxygen and combustible gases,
thus exerting excellent suffocating effect.”

11. US Naval Research Laboratory’s (NRL) Jun. 2019 research “Fuel for
Firefighting Foam evaluation: Gasoline v Heptane16” found that:
• Four leading commercial F3s required between 2.5 times more and over 6 times more F3 than the
benchmark C6-AFFF, when required to extinguish gasoline fires in 60 secs. These differences
widened as extinction speeds became faster.
• Further investigation showed “Individual major components of gasoline were tested, and the
aromatic components were determined to be the source of this difficulty in gasoline fire
suppression.” Essentially the aromatics extracted surfactants from the F3, prematurely
attacking the foam blanket. These aromatics are absent in the widely used fire approval test fuel
heptane, but occur at lower concentrations in Jet A1 aviation fuel, probably explaining why F3s
often struggle extinguishing fires involving Jet A1, seeming to cause persistent edge flickers (ICAO
extended their extinguishment time to 120 secs in 2014 - from 60secs previously).
• Most current international approval ratings (eg. EN1568-3, ISO7203-1, UL162, Lastfire, FM 5130,
IMO) seem to provide a distorted ‘better than reality’ impression of F3s ability on flammable fuels
like gasoline, because they use the easier test fuel heptane, which is rarely if ever stored or used
in bulk at industrial facilities.
• This research suggests that at higher ambient temperatures these aromatics would be more
volatile and actively vaporising from the fuel, making the fire more intense and difficulty to
extinguish, while also diffusing into theF3 foam blanket, potentially leading to premature collapse
or re-ignition (particularly relevant to Jet A1 –flashpoint 38oC - during hot summers like 2021 -
2023, widely experienced across US, EU and parts of Asia, including Australia in 2018-19).

Submission to CASA – High temperature Foam verification at Australian Airports 9
• NRL suggested a well-defined “TMB-heptane mixture could be developed for gasoline sensitivity
testing of F3 formulations to diagnose extinction shortfalls that heptane pool fires will not
detect.” UL 162’s TC previously suggested safety concerns with this suggestion, so a suitable
alternative is needed. Current knowledge suggests this has not been adopted by any fire testing
approval body so far (nor any suitable alternative).
• Interestingly Safety Data Sheets (SDS) for Jet A1 fuel confirm these same 4 aromatics are also
present in Jet A1, but at lower quantities than gasoline, which may help to explain why F3s often
struggle with Jet A1 fires under ICAO Level B and C, to the extent that the previous 60 second
extinguishment time was extended in 2014 to 120 secs to allow persistent edge flickers frequently
found when F3s were tested to be accepted as a ‘PASS’.
• NRL also found “Two diagnostics that relate valuable information about foam-fuel interaction are
a foam degradation test and a fuel-vapor transport test. Foam degradation was evaluated by
monitoring the disappearance of a 4 cm thick layer of laboratory generated foam deposited over
60 ml of 35⁰C heptane or gasoline in a 100 ml beaker. There is an increase in bubble size followed
by a shrinking of the foam volume. A plot of foam height vs time depicts significant foam
degradation differences between the heptane and gasoline fuels.” It would be interesting to
determine whether this accelerates as fuel temperatures rise further towards 50oC?
• This research suggests that at higher ambient temperatures these aromatics would be more
volatile and actively vaporising from the fuel, making the fire more intense and difficulty to
extinguish, while also diffusing into theF3 foam blanket, potentially leading to premature collapse
or re-ignition (particularly relevant to Jet A1 –flashpoint 38oC - during hot summers like 2021 and
2022, widely experienced across EU).

This might also help explain why a Boeing 777 aircraft fire in Dubai (Aug.2016) was unable to be
extinguished for 16 hours when the investigation report clearly confirmed F3s were used. A
catastrophic disaster was only just averted by rapid evacuation of all 282 passengers just 90
seconds before a fuel tank exploded, tragically killing a brave firefighter. Had there been infirm or
disabled passengers, perhaps parents with babies or young children, which could inevitably have
delayed evacuation, carnage could easily have resulted. The F3 used was unable to extinguish the
fire and the plane was destroyed (see details in 24 ii below). We should all learn from this spine-
chilling ‘near-disaster’.

12. NRL’s Nov. 2019 paper “Characterising role of Fluorocarbon and Hydrocarbon
surfactants in Firefighting Foams for fire suppression17” confirmed that:
• “foam spread, foam degradation, fuel transport, and fire extinction times of hydrocarbon
surfactants are significantly inferior to the fluorocarbon surfactant containing formulations.”
• Concluding “Trends in fire extinction among the surfactant formulations can be related to the
trends in foam degradation, fuel transport, and foam spread rates.”

13. NFPA’s Research Foundation 2020 ‘Evaluation of F3s report’18 tested five UL162
listed F3s, two for hydrocarbon fuels and three for multi-purpose Alcohol Resistance (AR),
using forceful and gentle applications, different fuels (heptane, gasoline, E10 [gasoline
with 10% Ethanol added] and IPA [IsoPropylAlcohol]) using low expansion ratios of 3-4:1
and regular expansions of 7-8:1. 165 fire tests were conducted. it found:
• “fires involving boiling flammable liquids are much harder to extinguish than fires that are
combatted prior to the transition into boiling.” – implying fast effective agents deliver a
benefit over slower less effective F3s.

Submission to CASA – High temperature Foam verification at Australian Airports 10
• “[F3] Expansion ratios of 3-4:1 required double the density of 7-8:1 expansion
application.” Existing fire systems equipment is often integral to fire trucks and other
infrastructure. Such integral systems are not easily removed, re-engineered, modified,
cleaned or replaced as it is designed specifically for effectively controlling fires fast. Space
and weight restrictions apply, so adding extra concentrate for higher application rates,
heavier and larger higher aspirating delivery devices (with higher expanded foam
potentially blown away by wind/motion) is not a practical or economic option. This could
result in likely unacceptable increases in risk to lives and increasing risk of catastrophic
fires.
• “To summarize the results, the baseline [C6] AR-AFFF demonstrated consistent/superior
firefighting capabilities through the entire test program under all test conditions. For the
FFFs [F3s] in general, the firefighting capabilities of the foams varied from manufacturer
to manufacturer making it difficult to develop “generic” design requirements.”
• “The FFFs did well against heptane but struggled against some of the scenarios
conducted with IPA and gasoline (both MILSPEC and E10), especially when the foam was
discharged with a lower foam quality/aspiration.”
• “The FFFs required between 2-4 times both the rates and the densities of the [C6] AR-AFFF
to produce similar results against the IPA fires conducted in with the Type II [gentle] test
configuration.”
• “During the Type III [forceful] tests, the FFFs required between 3-4 times the
extinguishment density of the AR-AFFF for the tests conducted with MILSPEC gasoline
and between 6-7 times the density of the AR-AFFF for the tests conducted with E10
gasoline.”
• “From an application rate perspective, the FFFs typically required between 1.5 to 3 times
the application rates to produce comparable performance as the baseline AFFF for the
range of parameters included in this assessment.” There is no extra space or weight
allocation for 2 or 3 times more foam volume in many Defence assets, Offshore
platforms, ships or even Aviation fire trucks. There is also no known evidence of F3
effectiveness in these sectors. Defence (which works with knowns, not ‘unknowns’
wherever possible) is a key example. This makes proposed use of F3s largely untenable by
Defence, Offshore, Shipping, Aviation fire trucks etc. on Workplace Health and Safety
grounds alone.
• Paraphrasing… ‘F3 was not a ‘drop-in’ replacement for C6 AR-AFFF even using
freshwater as individual products varied significantly, making it difficult to develop
‘generic’ design requirements.’
• Variable viscosity, proportioning & discharge performances were found across F3
products tested.
• “For the FFFs [F3s] in general, the firefighting capabilities of the foams varied from
manufacturer to manufacturer making it difficult to develop “generic” design
requirements.”

14. US Naval Research Laboratory’s (NRL) May 2020 report19 on F3 fire testing over a
MilSpec 28ft2 (2.6m2) pool fire of gasoline confirmed:
• “Performance of the fluorine-free foams improved when the fuel was switched to
heptane and when the solution application rate was increased from 2 gpm to 2.5 gpm
with both fluorine-free foams extinguishing the [heptane] fire in 31 seconds.”

Submission to CASA – High temperature Foam verification at Australian Airports 11
• “Interestingly, AFFF-1 does not appear to have a significant dependence on solution
flow rate, the change in extinction performance is negligible between 2, 2.5 and 3 gpm. …
Both fluorine-free foams had slower drainage and slower bubble coarsening than the
commercial AFFF. However, foam properties collected do not appear to correlate well
with extinction performance”
• “A significant improvement in fire suppression over gasoline was not seen for the fluorine-
free foams when the liquid application rate increased from 2.5 to 3 gpm.”
• “The inability of the foams and concentrates to meet critical extinction and property
metrics for military qualification testing indicate the difficulties of utilizing these
commercial products for Navy operations [ie whenever saline water is used].” This
similarly applies to Offshore, shipping, some refinery, Petrochem and industrial facilities.

15. US Dept. Energy’s 2020 Battelle research20 assessed seven commercially available
PFAS-free Foams (F3s) finding:
• F3 viscosity up to 90,000centistokes were possible, although significantly reduced in warmer
25oC conditions. This is not representative of most commonly occurring Offshore or Defence
operational conditions, nor most sectors in EU during winter. Potential to cause reduced
proportioning or potentially complete blockage at low operational temperatures, preventing fire
control.
• Compressed air foam (CAF) delivery (a development not currently used offshore nor in other
sectors) reduced extinguishment times (but not enough to pass MilSpec). Standard Mil-Spec test
nozzle extinguishments with CAF varied from 60secs to 200 secs on 28ft2 Mil-Spec fire requiring
30second or less extinguishment time to pass.
• Only three of the seven F3s was able to pass Mil-Spec’s burnback test, increasing the risk of
flashbacks and re-involvement of the fire.
• In corrosion testing, four of these seven F3s attacked Cupro-Nickel, one of which also attacked
Bronze, materials generally used for their resistance to seawater corrosion.

16. Australian 2021 seawater compatibility research (Dlugogorski and Schaefer)21
confirmed:
• “The [foam] chemical compatibility with seawater is related to the formation of the specific
ionized species that combine with divalent alkaline earth-metal cations to form ionic assemblies
in the premix (solution made by mixing foam concentrate with water). These species arise at high
pH values that are characteristic of seawater. “
• “Thin films that exist between foam bubbles and made of mixtures of fluoro- and hydrocarbon
surfactants are markedly stable in contact with hot fuels [1] in comparison to those of fluorine-
free foams (FFF). Foam blankets and individual films are also exceptionally effective in
controlling the transfer of flammable vapours from the hot fuel to the gas phase, the process
that sustains a fire [2].”
• “In addition, mixtures of fluoro- and hydrocarbon surfactants induce the formation of thin films
usually less than 50 µm in thickness [3], that spread on the fuel surface in front of the advancing
foam blanket. These films provide the initial cooling of the fuel at the air interface and form the
barrier to diffusion of fuel vapours, as illustrated in the schematic of Fig. 1.”
• “The physical compatibility of fluorosurfactants with seawater manifests itself by shielding of the
ionised head groups by metal cations decreasing the surface tension and modifying the size, shape
and diffusion of micelles.”

Submission to CASA – High temperature Foam verification at Australian Airports 12
• “We also reveal that changes in the ionization state of amine-oxide and tertiary-amine head
groups, as pH varies between that of fresh and seawater premix, may impact the performance
of fluorosurfactants [generally providing superior seawater tolerance in fluorinated firefighting
foams than PFAS-free alternatives].”
• “For foam concentrates that satisfy the necessary condition of chemically compatible with
seawater, the physical effect usually improves the foam quality and the fire-suppression
performance of AFFF.” This is not found to be the case with most PFAS-free foams without
fluorosurfactants present.
• “The sealing and cooling properties of the spreading films and foam blankets comprise the two
most important characteristics of foams made from solutions of fluoro- and hydrocarbon
surfactants.” These factors apply to C6-AFFFs but not F3s without these unique ingredients.
• These essential benefits are critical in defence sector to deliver reliable and rapid fire control
within the 30 secs ‘cook-off’ time for munitions, which is not currently available from PFAS-free
foam (F3s) alternatives. It also strongly relates to Offshore installations and shipping.

17. FAA issued a Cert Alert 21-05 (Oct.21)22 of F3 public safety concerns from test findings
(formally reported in Jul.2022 below) which led to confirming:
• “While FAA and DoD [Department of Defense] testing continues, interim research has
already identified safety concerns with candidate fluorine-free products that must be
fully evaluated, mitigated, and/or improved before FAA can adopt an alternative foam
that adequately protects the flying public”.
• “The safety concerns FAA has documented include:
o Notable increase in extinguishment time;
o Issues with fire reigniting (failure to maintain fire suppression); and
o Possible incompatibility with other firefighting agents, existing firefighting
equipment, and aircraft rescue training and firefighting strategy that exists
today at Part 139 air carrier airports.”
• While FAA and DoD continue the national testing effort, the FAA reminds all Part 139
airport operators that while fluorinated foams are no longer required, the existing
performance standard for firefighting foam remains unchanged (whether that foam is
fluorinated or not).”
• “Airports that are currently certificated under Part 139 will remain in compliance
through use of an approved firefighting foam that satisfies the performance
requirements of MIL-PRF-24385F(SH) [ie.…F3s were not excluded, so if they pass all
tests accepted for used].”

18. US Federal Aviation Administration (FAA), July 2022 Fluorine Free Foam
Testing Report TC22-2323 confirmed seven F3s were tested under MilSpec and ICAO
level C protocols against two C6-AFFFs. Modified tests included MilSpec with 10 sec &
90sec Jet A fuel (not gasoline), UNI86 (2gpm) nozzle, fixed Mil & UNI86 nozzles (2gpm).
It found:
• “The gasoline fires were significantly more difficult to extinguish and more volatile in
their reactions to foam applications. Flareups, fuel pickup, and surface burning were
more commonly observed in the gasoline fires compared to the Jet-A fires.”

Submission to CASA – High temperature Foam verification at Australian Airports 13
• “The test fuel also had less of an impact on burnback results than extinguishment
results.”
• “The quality of the foam generated also significantly impacted the results. Fuel pickup
and surface burning were commonly observed when the foam was discharged at a
reduced pressure, even with AFFF when not seen in other tests.”
• The best F3 on MilSpec gasoline extinguishment time was 38% increase over AFFF.
• “None of the FFFs [F3s] evaluated had an equivalent extinguishing performance to
AFFF. . …In all the nominal concentration gasoline fires, none of the FFFs evaluated
were able to extinguish the fire in an equal or lesser amount of time.”
• “Of all the Jet-A test fires, only one of the scenarios, the ICAO test fire, resulted in
extinguishment times of a FFF that surpassed the performance of AFFFs consistently,
with both foams achieving extinguishment well after the foam application had been
completed.”
• …All the other Jet-A fuel fire scenarios resulted in extinguishment times of FFF
candidates significantly slower than AFFF.”
• “One candidate FFF did have significantly greater burnback protection than AFFF while
the remaining FFF candidates’ burnback protections were significantly less.”
• “This foam Chemguard C3IC1 AFFF was in fact the only foam examined that was able
to meet the ICAO Level C requirements during this series of tests.”
• “These newer formulations, referred to as C6 AFFF, are the products currently approved
for use at airports nationwide [across US].”
• “The FFFs’ extinguishment times had a much greater degree of inconsistency than the
AFFFs, which is attributed to the application techniques of the firefighters.”
• “Of note is the acute toxicity of the FFF candidates. As evaluated in this research effort,
all but one candidate did not meet the minimum LC50, indicating the candidates may be
more acutely toxic than the currently approved AFFFs.”
• Despite two F3s being ICAO Level C approved, no F3 passed the ICAO C tests - indoors
or outdoors with FAA.
• F3s did best in over-rich (15%) tests of 3% concentrate.
• Dry Chemical powders (notably potassium bicarbonate widely used throughout
aviation, defence, offshore, some shipping internationally) reduced performance of all
seven leading F3s tested under MilSpec and ICAO Level C3 protocols against two C6-
AFFFs.
• “All the tested FFFs exhibited reduced performance with the application of dry
chemical. … Since dry chemical is a common auxiliary agent and many ARFF vehicles
have dual-agent turret nozzles, this quality may pose significant safety issues in a real-
world response.” This also applies to helicopters, defence, ships machinery spaces etc.
• “Additionally, surface burning was a commonly observed trait of the FFF candidates
that is typically not observed with AFFF.”
• “Additionally, extinguishing the fire on the edges of the fire pans and preventing
reignition in these areas was generally more difficult with the FFFs than the AFFFs. In
the manual application evaluations, this difficulty was more evident and was
amplified by the application technique and cohesivity of the foam blanket.” This
confirms F3 use would become harder as pool fire sizes increased, and is directly
relevant to the need for rapid, effective first aid firefighting to prevent risk of escalation
across these six sectors.

Submission to CASA – High temperature Foam verification at Australian Airports 14
• “A direct discharge [of F3] into the pan or change in direction of application frequently
caused fire reignition in areas of the pan that were previously extinguished or pulled
the entire foam blanket away from other areas, causing reignition.” which could have
serious consequences as foam blankets are frequently disturbed and blown around
changing their direction by wind, on land and especially offshore, in defence, aviation
and shipping.
• “…this difficulty was more evident and was amplified by the [manual] application
technique. There appears to be a greater result of human bias in extinguishment
results with FFFs than AFFFs.” It is commonly experienced by firefighters that C6-AFFFs
are a more forgiving, effective, reliable and flexible agent, than alternative F3s.
• Five leading claimed ‘Fluorine Free’ Foams (F3s) were tested for Fluorine by an
independent laboratory, recording high 10-87ppm TOF (Total Organic Fluorine) by FAA
using US EPA 537.1 method24. This ridicules MilSpec’s 1ppb PFAS limit, far below ECHA’s
more practical and measurable 1ppm PFAS limit – STILL significantly exceeded.
• “Overall, none of the tested FFF candidates can be considered a direct replacement for
AFFF without compromising the efficacy of fire extinguishment.”

19. Sweden’s Research Institute (RI.SE) (Dahlbohm et al. Feb.2022)25 conducted
extensive fire performance testing on eleven F3s. It concluded:
• “A general trend is that sea water, i.e. water containing a strong electrolyte (sodium
chloride), negatively impacts [F3] fire test performance, which is a general expectation.
• The impact of sodium chloride on foam drainage was investigated by Burcik [30] and
later by Shah [31]. Both studies concluded that the addition of a salt to an aqueous
solution of an ionic surfactant decreases the surface tension and enhances the rate of
equilibrium surface tension attainment ie. increases the rate of foam collapse.”
• With one F3 “When the foam concentrate was mixed with sea water, precipitations
were immediately formed.”
• “Testing in seawater generally prolonged [F3] extinguishment times, or prevented
extinguishment.”
• When seawater was used only two F3s extinguished (2min47s and 4min11s), nine F3s
did not extinguish (EN1568-3). “This is assumed to be due to interactions with the fuel
causing rapid breakdown of the firefighting foam.”
• Only three of these eleven F3s using freshwater were found to extinguish ICAO Level B
in under 2 mins requirement, 3 did not extinguish at all.
• Five of these 3% F3s were also tested at 4.5% admixture (1.5x rich), only one
extinguished in 1min59s.
• None of eleven F3s when forcefully applied, extinguished EN1568-3 [heptane] within
required 1min30s. Only 5 extinguished (best 2min30s, worst 5min 35s), 6 did not
extinguish.
• “The more forceful [F3] application, the greater the fuel pick-up.” Emphasising the
importance of gentle applications with F3s, which is not possible or usually ineffective
offshore, in defence, aviation, and most transportations.

Submission to CASA – High temperature Foam verification at Australian Airports 15
• Results also indicated time to fire knockdown decreased with decreasing foam
viscosity (F3s are generally more viscous than AFFFs), and CAFs showed higher
extinction and burnback performance than UNI86.
• “None of 11 products outperformed rest. …None met fire test performance requirements
in all ref. Standards. Instead they seem to perform best in different niches – certain
fuels or water.”
• ” If the foam breakdown or fuel pick-up is too large, extinction times may instead be
longer. … a higher heat flux increases the firefighting foam breakdown.”
• Diesel was stated as the easiest fuel.
• Interestingly one F3 extinguished diesel quickly in 1min23s (EN1568-3), but then failed
to extinguish two of the three heptane (EN) and Jet A1 (ICAO Level B) fires, reportedly
a rapid foam spread “in combination with the relatively low vapour pressure of diesel
and potentially a low fuel pick-up, may explain the short extinction time.” More
volatile fuels with higher vapour pressures often result in higher fuel pickup in the un-
protected F3 foam blanket, leading to premature decay or ignition.
• “This indicates fuel flashpoint as a good indicative parameter of firefighting foam [F3]
performance (also solubility of the fuel needs to be considered).” …” this addresses the
importance of evaluating firefighting foams using the fuel expected to be involved in a
fire, especially when it comes to FFFs [F3s}. An important conclusion from the
comparison of different fuels would be that it is important to perform tests in an
environment as close as possible to the real situation.” This includes realistic credible
events, under challenging and severe conditions likely to be experienced year-round
during major fire incidents which rarely match the ‘ideal conditions’ of testwork. Let’s
not forget Jet A1 has a flashpoint of 38oC well within hot summer temperatures,
increasingly exceeding 40oC across much of EU as experienced during recent
2021/2022 summers.
• Times to reach heat flux of 1.5kW/m2 (considered safe for personnel) showed small
variations (10-15s) using UNI86 nozzle, which may not be considered significant. Yet “On
the other hand, due to the drainage of firefighting foam, this time may be the
difference between success and failure i.e., an uncontrolled fire will eventually break
down the firefighting foam and again involve the entire fuel surface.”
• “ the fuel flashpoint could be an indicator of the complexity of firefighting.”
• None of eleven F3s was able to meet the 10min 25% burnback time (EN1568-3), only
one F3 exceeded this 10min requirement when used at an over-rich induction rate of
4.5% admixture (of nominal 3% foam).
• Testing confirmed “radiation induced drainage and evaporation as additional
parameters to ordinary drainage.”
• “a higher heat flux increases the firefighting foam breakdown.”
• “The firefighting foam generated by the UNI 86 nozzle spreads more easily and
suppressed the fire quicker than CAF. On the other hand, CAF is a more robust
firefighting foam having superior drainage properties, resulting in shorter extinction
times.”
• The IMO fire test uses gentle application (not forceful), so despite using seawater
(heptane) it is easier to pass, with seven F3s extinguishing within the required 5 mins.
Yet only two of 11xF3s passed forceful EN1568-3 (heptane) with seawater.
• “It may be concluded that the properties of the firefighting foam must be such that the
firefighting foam can rapidly spread over the surface and thereby suppress the fire but

Submission to CASA – High temperature Foam verification at Australian Airports 16
retain enough stability to prevent foam degradation caused by the fuel’s vapour and
radiation from the fire.”
• “All the findings and conclusions point out the importance to perform tests as close to
the real fire hazard situation as possible.” Implying this is critical to ensuring lives and
critical infrastructure are not unintentionally compromised.

20. NFPA Research Foundation’s 2022 ‘Fire Service Roadmap’ report26 confirmed:
• “The new fluorine-free foams are similar to the legacy protein foams in that they rely
solely on the foam blanket to contain the fuel vapors to extinguish the fire (i.e., fluorine-
free foams do not produce a surfactant film on the fuel surface like AFFF).” Evidence
from real fires under point 24 below shows comparative fire outcomes to understand
the unfolding catastrophic events that are more likely to occur due to a premature
transition to F3s in defence, aviation and neighbouring establishments to Seveso III
sites.
• “As a result, air-aspirating discharge devices may be required to optimize the
capabilities of these products.”
• “The research conducted to date suggests that FFFs tend to lose effectiveness when
discharged through non-air-aspirating nozzles that produce lower aspirated/aerated
foam with expansion ratios less that 4-5 (generally speaking).” Offshore, Defence,
Aviation and often transportation commonly uses non-aspirating discharge devices for
rapid control under wide ranging conditions including wind. Changing to aspirated devices
would likely reduce system effectiveness, increasing risks of catastrophic fires.
• …Specifically, reduced foam quality can be compensated for by increased application
rate and vice versa.”
• “…the fire protection industry relies heavily on the approval tests for defining the capabilities of
the foam as well as the extrapolation of these test results to actual applications by applying
factors of safety to the test results.”
• “The protocols are designed to verify specific capabilities and vary in difficulty depending on the
scenario in which it was intended to mitigate” As a result, a foam designed and approved for
DoD/Aviation applications may not perform well against a large petroleum industry fire (and vise-
a-versa). Yet there are no specific fire test approvals for challenging offshore applications.
• “There are many very effective FFFs on the market and in use today. However, it is
incorrect to assume that these new FFFs are a “drop in” replacement for AFFF even
though they may have a specific listing or approval. At this time, there is too much
difference between specific FFF's in properties and performance to suggest that the
class can be a drop-in replacement for the AFFF class of foams. Specific FFF foams
maybe used in place of existing specific AFFF foams in fixed systems or portable
application, but a detailed evaluation must be completed prior to making that
transition as described in this document.
• “In addition, fuel type is a significant variable and needs to be considered during testing
and foam selection. It needs to be noted that these approval tests are not designed to
simulate actual full-scale fire scenarios but rather to provide a means to assess the
capabilities of these products on an affordable and reproducible scale using many of the
parameters/conditions that makeup the industries’ Maximum Credible Event (MCE).”
Many of these fire test approvals only use heptane which is rarely used, transported or
stored in bulk, so can be misleading regarding effectiveness on more volatile hydrocarbon

Submission to CASA – High temperature Foam verification at Australian Airports 17
fuels like condensate, naphtha, crude oil, Jet A1 etc. which are more relevant offshore, in
Shipping, Storage and Transportation, neighbours to Seveso III refineries etc. Defence also
uses some ‘exotic ‘fuels.
• Useful warnings include: “As a high-level overview of the state of the industry, a recent literature
search identified between 60-70 commercially available products that were being marketed as
“environmentally friendly” AFFF alternatives. A deeper dive into this information revealed that
about one-half of these products did not have legitimate approvals and/or listings and were
being marketed strictly on limited ad-hoc testing and associated videos. The remaining products
have been tested to, and/or listed/approved to the legacy test protocols.” …These
predominantly use heptane which can be misleading, particularly with F3s.
• “However, it is incorrect to assume that these new FFFs are a “drop in” replacement for
AFFF even though they may have a specific listing or approval. At this time, there is too
much difference between specific FFF's in properties and performance to suggest that
the class can be a drop-in replacement for the AFFF class of foams.”
• “Specifically, one pass of a stream of AFFF typically extinguished all the fire in application,
including on the far side of smaller obstructions. Conversely, the FFFs tended to leave
small holes in the foam blanket and needed more agent to extinguish all of the obstructed
fires. In short, the FFFs typically took two passes of foam application to match the single
pass of AFFF explaining the 1.5-2 times longer extinguishment times.”
“As a result, these conditions could have been even more pronounced if the tests had
been conducted with a flammable liquid like gasoline. … pre-fire planning and training
will be key to successful implementation/deployment of these products going forward.”
• “Although these new foams are being developed and implemented as environmentally
friendly AFFF alternatives, the industry trends will require collection and disposal of
these [F3] products in the same manner as AFFF is being handled today. So
unfortunately, the ability to train with these foams will have the same cost burden as
the legacy AFFFs requiring special facilities and waste containment/collection. As a
result, innovative training approaches (e.g. immersive reality approaches) should be
considered/developed to more effectively and efficiently address the increased
challenges of transitioning to these new products. Additional training resources will be
required to address new foam alternatives (e.g., model procedures, model strategies or
tactics with new foams, training facilities, equipment transition, etc.). Special education
and training are needed for foam stewardship (e.g., why the transition is needed, why
environmental contamination is important,” This training intensity, foam disposal and
significant costs per firefighter have not been adequately considered in this restriction
proposal so far.
• There are no F3 alternatives which currently meet all existing C6-AFFF capabilities, nor
has passed the existing AFFF MilSpec31,32, new F3 MilSpec 32725 (by early May 2023)29,30,
or UL162 seawater accreditation27,28 with non-aspirating devices under necessary
operating conditions of -18oC, widely experienced across EU in winter, particularly
Offshore, in Defence, Shipping and other sectors, including Seveso III sites.
• “Ultimately, end users will need to design and install within the listed parameters in
order to ensure a high probability of success during an actual event. This applies to both
the discharge devices and proportioning system.” Implying to avoid the potentially very
high impacts of even a single catastrophic fire on human health and the environment
which could occur if those risks are not kept as low as they are currently by using C6-
foams like C6-AFFFs.

Submission to CASA – High temperature Foam verification at Australian Airports 18
These are critical life-saving considerations at industrial facilities, justifying the
proposed UL changes, to avoid the potentially very high impacts of even a single
catastrophic fire on human health and the environment which could occur if misleading
results are not addressed appropriately by changes to UL162.

21. US Department of Defense (DoD) NEW fire performance test standard MIL-PRF-
32725 for Fluorine Free Foams (F3s) issued in Jan.202329, specifically designed for land-
based operations using freshwater only.
• It is not accepted for Naval use, clearly indicating that F3s meeting this specification are
not suitable for application in sea water because they are significantly less effective i.e.
UNSUITABLE.
• Any such qualified F3 also has to carry a warning label: “This product is not authorized
for US Navy Ship Board Use.” and “Do not mix with other foam concentrates.”
• This standard also seems considerably weakened by:

• Single 50ft2 (4.64m2) fire test uses freshwater and 3gpm nozzle [50% higher application
rate] on Jet A in 60sec extinction and 270sec burnback (not seawater and 2gpm nozzle on
gasoline in 50 sec extinction and 360sec burnback as AFFF MilSpec– a much harder test) -
potentially placing lives at increased risk.
• 2 passes from 3 attempts (only 66% success) per test (100% pass rate currently required
to pass) -eroding this important safety factor.
• 28ft2 (2.6m2) fire tests use Jet A with 10sec preburn - unrealistically short, avoids heat
build-up (not gasoline & 10sec preburn)
• Only two 28ft2 (2.6m2) tougher fire test with gasoline (new and aged [10 days at 65oC]
F3 concentrates), 2gpm nozzle, 10sec preburn, 60sec extinction, 240sec burnback –
freshwater only (not gasoline, 2gpm nozzle, 10sec preburn, 30sec extinction and 360sec
burnback with fresh and seawater). Is that tough enough?
• Burnbacks now start after 30secs (not within 60 secs ie. 55-58secs for AFFF spec) reducing
protections for anyone trapped and risking faster re-ignition.
• Dry Chemical compatibility uses Jet A and freshwater (not gasoline and SEAwater)
making it easier to pass.
• ALL fire tests conducted between 5 and 32oC ambient temps, making it much easier to
pass at 5oC - unrepresentative of year-round conditions!
• Wind speed reduced to 5mph (not 10mph) - so less blanket disturbance, also making it
easier to pass.
• Viscous concentrates - kinematic viscosity 300cs at 25oC (not 2cs for AFFF). NO
requirement at 5oC – when more relevant operationally (AFFF is 20cs at 5oC).
• Corrosion rates now tested with just 10% F3 diluted in 90% seawater (not 90% AFFF
diluted in 10% seawater) – unrealistic - presumably seawater is less corrosive than F3s?
• Aquatic toxicity LC50 requirement now reduced over 16-fold to 30ppm with more
tolerant Fathead Minnow specified – a pollution tolerant species (not 500ppm with
more sensitive Killifish required under AFFF MilSpec).
• F3 PFAS content <1ppb potentially unrealistic – particularly when five leading F3s each
tested 10-87ppm to PFAS as Total Organic Fluorine (TOF) by FAA in Jul.2022 report (using
US EPA 537.1 method24).

Submission to CASA – High temperature Foam verification at Australian Airports 19
• NO F3s are currently qualified to this spec in early May 202330. Yet ten C6-AFFF 3% foams
are currently qualified to the existing MilSpec MIL-PRF-24385F(SH)v4, 202031,32.
• This existing AFFF MilSpec32 also permits F3 use offshore - providing any such F3 has been
qualified by passing ALL the detailed fire performance tests in fresh and saltwater
required by this 24385F specification – no F3s can pass these tests – even freshwater
only31, hence the arrival of a test designed just to allow F3s to pass.

22. FAA issued Cert-Alert 23-01 (Jan.2023)33 in response to this new MilSpec:
• Accepting airport use of this new F3 spec. once F3 passes qualification testing and is
added to QPL/QPD.
• “Currently, Certificated Pt.139 airports will not be required by the FAA to transition to
the new F3. Airport operators are authorised to continue using QPL MilSpec AFFF”.
• “F3s lack compatibility with other F3s, so they cannot be mixed together.” Also F3s are
not premixable.
• “Airports using potassium based dry chemical should contact their assigned FAA Airport
Certification Safety Inspector to discuss options for ARFF response” …as F3s can be
instantly attacked by Dry Chem applications.

Submission to CASA – High temperature Foam verification at Australian Airports 20
23. Lastfire testing, 2016-202234
A wide range of ad hoc testing criteria are used (not always realistic to real-life events) to
address specific user questions for quite specific tank storage applications. Operational application
rates are used as ‘test rates’ in some tests without specific safety factor recommendations
compensating for virtually ideal fire test conditions, which require consideration. Detailed fire test
results are often not publicly available, but more positive conclusions are often drawn focusing
on best F3 outcomes, sometimes from single F3 agent results (summarised from NFPA 11:2021
Annex H).

Test criteria used include:
• Small scale test series to EN1568 (Parts 3 and 4) and Lastfire using 5x F3s, C6 and C8-AFFF.
• Small scale 5m2 and 20m2 spill fires, varying application techniques (incl. plunging [Type 3] semi-
aspirated and aspirated monitor nozzles, more gentle [Type 2] medium expansion, Compressed Air
Foam System [CAFS] and system pourer /foam chamber).
• Proportioning tests – venturi, in-line and displacement pumped proportioning.
• Large scale tank 11m dia. x 9m tall (100m2) CAFS application rate 75% of conventional foam delivery.
• Long flow 30m and 40m, single F3 on Jet A, conventional (4L/min/m2) and CAF pourer (2L/min/m2),
single F3, both delivering extinguishment.
• Subsurface application single F3 on Jet A (based on UL162).
• Vapour suppression tests F3s and C6AFFF under fire and non-fire situations using vapour detectors.
• Hybrid monitor test.
• 20m bund flow, single F3 using system pourer with obstructions in path, successfully extinguished
using approx. 75% of typical design application rate.
• Additional F3 in 11m dia. tank, extinguished using approx. 75% normal design application rate.
• Small-scale Lastfire testing of Self-Expanding Foam (SEF) using F3 (premix under CO2 pressure,
activation generates bubbles).
• Variety of fuels used throughout tests, incl. heptane, gasoline, crude oil, Jet A/A1 and ethanol.
• Some tests included saltwater and freshwater. At times compatibility with dry chemical also
assessed.

Summary results found:
LASTFIRE’s testing programs have resulted in important findings aimed at application of new
generation F3s, including the following:
• “LASTFIRE concluded that some FFFs [F3s] are suitable for some applications, including hydrocarbon
spill fires and smaller storage tanks subject to validated testing on the specific foam and application
device.”
• Not possible to be generic in terms of performance of this type of foam concentrate [F3] on any
specific fuel.
• Foam performance is dependent on application equipment as well as foam concentrate and
application rate – particularly true of F3s as all work more effectively with aspirated equipment.
• Some F3s with high viscosity might require proportioning system modifications to ensure a pick-up
rate within acceptable tolerances.
• No foam of any type should be regarded as a ‘drop in’ replacement without full evaluation.
• Compressed Air Foam (CAF) can provide effective extinguishing with F3s at lower application rates
than conventionally aspirated equipment, subject to validation through testing for a specific set of
circumstances.
• Important that a validated test method specifically relevant to the application is used to determine
system design characteristics.
• Smaller tank fires (11m) have shown effective performance can be achieved with some foam and
equipment combinations – this has not been validated in larger scale testing.

Submission to CASA – High temperature Foam verification at Australian Airports 21
• It is recognised a major knowledge gap still exists in application of any new generation foam but
particularly F3s to larger tank fires using large throughput monitors, especially non-aspirating types.
• Important records (to verify what has been done on site) form valuable parts of any results
reporting.
• Further phases of testing are planned.

24. Evidence from real fires
There is remarkably little evidence from large scale operational fires where F3 has been used, to give us any assurances of effectiveness. What is evident from even small fires is not very convincing and highlights some disturbing traits.

Some major airports have already transitioned to Fluorine Free Foams (F3s), fully accepting small scale International Civil Aviation Organisation’s (ICAO) Level B, (rarely the tougher Level C) approval and local testing as adequate indicators of likely F3 ‘success’, should the worst happen. Some have also relied on claimed ‘successes’ at London
Heathrow (LHR), which the specific Air
Accident Investigation Reports confirm are misleading.

2015 Air Accident Investigation Reports confirmed An Airbus A319 engine fire at
LHR (May2013)26 was controlled, almost extinguished by on-board fire suppression systems, before landing.
Calculated fuel leakage rates reportedly emptied the wing tank, before landing, when some F3 was used under non-challenging situations. The fire was quickly extinguished prior to safe passenger evacuation. Whilst this was a significant incident, May temperatures are quite cool in UK, and it could hardly be claimed as a major fire or major performance ‘success’, since only a small fire in the right engine was involved56, seemingly requiring little foam agent.

A further Boeing 787 fire at LHR (July 2013)57 occurred when unpowered, unoccupied, and parked.
Firefighters extinguished a small slow-burning composite material cabin roof fire (likely from Li-ion battery fault), using a water hose-reel internally. A small amount of foam was used externally without impacting the fire (probably unnecessarily) as no fire penetrated the fuselage. This could not be considered a serious incident, nor an example of operational effectiveness of F3’s capability. No surprise that claimed clean-up costs were ‘zero’.

Without direct proof of efficacy in major aircraft fires so far, questions remain about the viability of such foams under challenging operational conditions, since there appear to be no reports of F3 use on major fires at airports -except Dubai (covered in 1.10 above).

Have we, should we, be adequately considering potential F3 liabilities and consequences during major aircraft fires like Dubai or Singapore - before disaster strikes? FAA seems to have done. …How would
Australian airports using only F3s perform under severe temperature conditions of 40oC or above, regularly experienced at up to 16 airports with ARFFS, as BOM data confirms4?

Submission to CASA – High temperature Foam verification at Australian Airports 22
25. Summary Comparison Table: 2023 F3 MilSpec 3272529 v AFFF MilSpec 24385F(SH)v4
202032. New F3 Milspec seems more similar to ICAO Level B than C!

Criterion FLUORINE FREE FOAM (F3) AFFF & F3
US Mil Spec 32725 US Mil Spec24385F (SH)v4
2023 spec. (3%) 2020 spec. (3%)
Suitability Land-based: fresh water Land and Sea: Fresh
ONLY AND SEA water
Warning labels – “F3 liquid concentrate for
every drum LAND-BASED, FRESH WATER NO specific warnings
APPLICATIONS”
“NOT AUTHORIZED FOR US Type 3% or 6%
NAVY SHIPBOARD USE” Mil Spec AFFF Liquid
“DO NOT MIX WITH OTHER Concentrate
FOAM CONCNETRATES” Storage not below 35oF
“Contents contain max. 1ppb (1.6oC)
PFAS” and avoid prolonged
Storage not below 35oF storage above 120oF (
(1.6oC) 48.8oC)
or above 120oF ( 48.8oC)
Pool fires used - Circular 28ft2 (2.6m2) Circular 28ft2 (2.6m2)
Small: Circular 50ft2* (4.64m2) Circular 50ft2* (4.64m2)
-
Large:
No. fire tests 1x large Jet A; 8 x small –2 x 1x large; 7x small
28ft2 gasoline (3% aged, 3% (fresh and SALT water)
unaged) ALL Gasoline
Rest ALL Jet A
Fuel type – fire tests Jet A (except 2 small gasoline ALL Unleaded gasoline
fires)
Passes required 2 of 3 attempts (66% ALL must pass (100%
success!) success)
Fuel quantity 10 gals (37.85L, water base) - 10 gals (37.85L, water
28ft2; base) -28ft2; 15 galls
15 galls (56.77L, water base) - (56.77L water base) - 50ft2
50ft2
Foam nozzle & flow Mil spec 2 gal/min (7.5L/min)
rate -28ft2 Mil spec 2 gal/min
Modified 3gpm nozzle – 50ft2 (7.5L/min) 28ft2 and 50ft
(50% higher application rate) fires

Nozzle pressure 100psi (7 bar) 100psi (7 bar)
Foam expansion Min 7:1 Min 5:1
ratio

Submission to CASA – High temperature Foam verification at Australian Airports 23
Application density 0.07g/ft2 (2.87L/min/m2) 0.07g/ft2 (2.87L/min/m2)
(small) 28ft2 28ft2
ALL fresh water ONLY) Using fresh AND SEA water

Application density 0.06g/ft2 (2.46/min/m2) 50ft2 0.04g/ft2 (1.64L/min/m2)
(large) on JetA 50ft2‡
Fresh water ONLY SEA water ONLY
Ambient temps. 5-32oC NR
Foam solution 17-28oC 17-28oC
temps.
Fuel & water base 10-32oC NR
temps.
Nozzle movement Forcefully into fuel, free Forcefully into fuel, free
movement movement
Total Fluorine <1ppb TOF (total organic <800ppb PFOA; <800ppb
content Fluorine) PFOS
Max. viscosity 300cs 20cs
(kinematic) at 5oC
Foam % tests 3%; 1.5 % (lean) #†; 6% 3%; 1.5 % (lean) #†; 15%
(rich)*† (rich)*†
Fire pre-burn time 10 secs Jet A1 28ft2 10 secs on all 28ft2 and
60secs Jet A1 50ft2 50ft 2 gasoline fires
10secs gasoline 28ft2
Foam water quality Fresh ONLY – ALL fires Fresh & SALT water ‡
Foam application 90 secs 90 secs
time
Total extinction 30 secs (3%, 1.5%, 6% - 28ft2 30 secs (3% AFFF & Aged)
(pass) Jet A) Fresh & Sea water
60secs Aged F3 (3% -28ft2 Jet 45 secs (1.5%) fresh and
A) sea water
60 secs (3%- 28ft2 gasoline) 55 secs (15%) -28ft2 Sea
60 secs (3% -50ft2 Jet A 75% only
out in 20secs) 50 secs - 50ft2 Sea only
Burnback pot 0.3m dia, 50mm tall, 0.3m dia, 50mm tall,
size/fuel (both 1 gal ULG (3.785L) 1 gal ULG (3.785L)
centre tray)
Burnback pot 30secs after foam application Within 60secs after foam
ignition time application (implied 55-
58secs)
≤25% tray Burnback 5 mins (3%, 1.5%, 6% - 28ft2 6 mins (3%,# 3% Aged #
re-involvement time Jet A) 28ft2)
(pass) 4 mins Aged F3 (3%. 1.5% - 5 mins (1.5%# -28ft2)
28ft2 Jet A) 3.3 mins (15%* - 28ft2)
4 mins Dry chem (28ft2 Jet A) 4 mins Dry Chem – 28ft2
4mins (Aged 3%- 28ft2 6 mins -50ft2*
gasoline) ALL Gasoline
4.5mins (3% -50ft2 Jet A)

Submission to CASA – High temperature Foam verification at Australian Airports 24
Total fire tests to 9 7
Qualify/Certify as Fire extinctions & burnbacks, Fire extinctions &
Passed Fesh – mostly Jet A , Dry burnbacks, fresh and
Chem, after 10 day 65°C seawater, Dry Chem, after
10 day 65°C ALL gasoline
Corrosion tests Uses 10% F3 with 90% Uses 90% AFFF with 10%
SALTWATER SALTWATER

Compatibility with 30 sec extinction – Jet A1 30 sec extinction - gasoline
Dry Chemical 28ft2 ≥4 mins burnback ≥4 mins burnback
fire test
Aquatic toxicity test LC50 ≥30mg/L (ppm) with LC50 ≥500mg/L (ppm) with
tolerant Fathead Minnow more sensitive Killifish
Biodegradability, 20 day Biodeg. 65% 20 day Biodeg. 65%
BOD/COD COD ≤900 mg/L (3%) COD ≤1,000k mg/L (3%)
Agents Qualified on NONE (early May 23) 10x C6-AFFFs
QPL Listing
Database
Key: = Harder; = Easier: = Potential danger; = Equivalent; NR =
Not Required; * = seawater test only; #= fresh and seawater tests; x= fresh water only
†= 28ft2 test only; ‡ = like UL162 fire test.

There are fundamental differences in safety provided by these two standards, with a significant
erosion of safety to lives and critical infrastructure by this new F3 MilSpec (more closely akin to
ICAO Level B than ICAO Level C). if it is unacceptable for protecting Navy personnel from
munitions cook-off, how can it be acceptable for munitions cook-off on land, which typically still
takes around 30secs, hence the criticality of requiring pool fire extinguishment of volatile
flammable liquids in 30 secs, which is not achievable by F3s even in freshwater, when existing
operational defence foams are required to achieve this key objective in 30 secs using fresh and
seawater. Requiring only 2 out of 3 attempts to pass each test, emphasizes the relative
unreliability of F3s and the extreme challenge this test poses to these concentrates, which are
conducted under virtually ideal test conditions, not the challenging operational environment
where it is intended to save lives. Safety factors are seriously eroded and FAA’s Jan.2023 Cert
Alert22 confirms US airports are not required to transition to F3s under this new MilSpec
Standard.

26. Comparison ICAO Level B/C3 v AFFF MilSpec Fire tests21 -What is missing?
Criterion US Mil F 24385F ICAO 2015 revision
2017 spec. (3%) Levels B and C (3%)
Fire tray shape and Circular 28ft2 (2.6m2) and Level B: Circular 4.5m2
area Circular 50ft2* (4.64m2) Level C: Circular 7.32m2
Fuel – fire test Unleaded gasoline Jet A1 or Kerosene
Fuel type – burnback Unleaded gasoline (1 Gal, 3.8L) Gasoline or Kerosene (2L)
pot

Submission to CASA – High temperature Foam verification at Australian Airports 25
Fuel quantity 10 gals (37.85L, no spec water Level B: 100L fuel
base) -28ft2; 15 galls (56.77L) - Level C: 157L fuel
50ft2 (over equal water bases)
Foam nozzle & flow Mil spec 2 gal/min (7.5L/min) UNI86, 11.4L/min
rate Modified Std nozzle Special high performance
nozzle
Nozzle pressure 100psi (7 bar) 6.3-6.6 bar
Concentrate storage 10 days @ 65°C NR
stability (pre-fire)
Application density 0.07g/ft2 (2.87L/min/m2) 28ft2 Level B: 2.5L/min/m2
(small) (fresh and saltwater) (single freshwater test only)
Application density 0.04g/ft2 (1.64L/min/m2) 50ft2‡ Level C: 1.56L/min/m2
(large) (saltwater only) (single freshwater only)
Ambient/foam temp. 23°C± 5°C (ie.17-28°C) ≥15°C (some certs. show 0°C)
Nozzle movement Forcefully into fuel, FFixed position
free movement
F and F-free allowed Yes Yes
PFOS & PFOA Measured NR
analysis
Total Fluorine Measured NR
content
Foam % tests 3%; 1.5 % (lean) #†; 15% (rich)*† 3% only
Fire pre-burn time 10 secs 60 secs
Foam water quality Fresh & Sea ‡ Fresh only
Foam application 90 secs 120secs
time
Total extinction 30 secs (3%), 45 secs (1.5%) 120 secs
(pass) 55 secs (15%), 50 secs 50ft2
Burnback pot 0.3m dia, 50mm tall, 0.3m dia,200mm tall,
size/fuel (both 1 gal ULG (3.785L) 2L ULG/Kerosene
centre tray)
Burnback pot 60secs end foam application 120 secs end foam
ignition time application
Burnback re- ≤25% tray in 6 mins (3%)#, 5 ≤25% tray in 5 mins
involvement (pass) mins (1.5%)#, 3.3 mins (15%)* (single freshwater test only)
6 mins (50ft2)*
Total fire tests to 6 1
Qualify/Certify as Fire extinctions & burnbacks, (fire extinction & burnback –
Passed fresh and seawater, after 10 freshwater only) – NO
day 65°C repeats
Film, sealing,
corrosion, ü NR
compatibility,
storage etc.

Submission to CASA – High temperature Foam verification at Australian Airports 26
Compatibility with ≥6 mins burnback NR
Dry Chemical fire
test
Aquatic toxicity test LC50 ≥500mg/L NR
Biodegradability, 20 day Biodeg. 65% NR
BOD/COD COD ≤1,000k mg/L (3%)
Strict drum & label ü NR
spec.
Qualified Agent ü NR
Database
Key: = Harder; = Easier: = Potential danger; = Equivalent;
NR = Not Required; * = seawater test only; #= fresh and seawater tests;
†= 28ft2 test only; ‡ = same as UL162 fire test.

This comparison shows ICAO Level C has a far slower extinguishment (ICAO 120sec v 30sec
requirement for MilSpec), does not include many important test parameters representative of
operationally challenging conditions (including rich and lean induction) for which safety factors
are used, but may not always be an adequate ‘surrogate’ for extra testing requirements. A
major failure is a single non-repeated fire test for certification at 15oC only.

Importantly ICAO requires:
• Only a SINGLE fire test using new concentrate to PASS (out of 100 attempts potentially) -
with no conformance testing or repeat re-qualification testing - ever.
• NO fire tests using aged concentrate (stored at 65oC for 10 days) to check storage stability
over time.
• NO half strength or over-rich fire tests to check still effective if proportioners should under-
perform.
• NO compatibility test with Dry Chemical, which can attack foam blankets, particularly F3s.
• Application rate on Level C fire test similar to MilSpec (but MilSpec has lower quality
nozzle), but easier Level B uses 57% higher application rate than MilSpec.
• Ambient and foam solution temps quite low at ³15oC (assisting a pass, some approval
certificates have shown 0oC, which should FAIL), with MilSpec 23oC (+-5oC).
• Higher performing, higher expansion special test nozzle which is not representative of
proprietary nozzles used widely by Aviation firefighters (ie easier to pass).
• Fixed nozzle position (harder) v moveable by firefighter in MilSpec.
• Longer foam application and shorter burnback time on less aggressive fuel, makes easier
to pass.

27. Comparison ICAO Level B/C3 v 2023 F3 MilSpec 32725 Fire tests29 - What is
missing?

Submission to CASA – High temperature Foam verification at Australian Airports 27
Submission to CASA – High temperature Foam verification at Australian Airports 28
This comparison shows clearly that ICAO Level B has a far slower extinguishment (ICAO 120sec
v 60sec requirement for 2023 F3 MilSpec) and does not include many important secondary test
parameters representative of operationally challenging conditions (including rich and lean

Submission to CASA – High temperature Foam verification at Australian Airports 29
induction) for which safety factors are used but may not always be an adequate ‘surrogate’ for
extra testing requirements. A major failure is a single non-repeated fire test for certification at
15oC only.
Importantly ICAO requires:
• Only a SINGLE fire test using new concentrate to PASS (out of 100 attempts potentially) -
with no conformance testing or repeat testing for re-qualification - ever.
• NO fire tests using aged concentrate (stored at 65oC for 10 days) to check storage stability
over time.
• NO half strength or over-rich fire tests to check still effective if proportioners should under-
perform.
• NO compatibility test with Dry Chemical, which can attack foam blankets, particularly F3s.
• Application rate on Level B fire test similar to F3 MilSpec - but MilSpec has lower quality
nozzle.
• Ambient and foam solution temps quite low at ³15oC (assisting a pass, some approval
certificates have shown 0oC, which should FAIL), with F3 MilSpec 23oC (+-5oC).
• ICAO uses higher performing, higher expansion special test nozzle which is not
representative of proprietary nozzles used widely by Aviation firefighters (ie easier to pass).
• Fixed nozzle position (harder) v moveable by firefighter in F3 MilSpec.
• Longer foam application could ensure better foam quality for burnback test, makes easier
to pass.

28. Evidence from three Major Fire comparisons: F3 use contributed to unacceptable outcomes: i. Defence fire comparison35-43

Submission to CASA – High temperature Foam verification at Australian Airports 30
i. Aviation fire comparison2,44

Submission to CASA – High temperature Foam verification at Australian Airports 31
Submission to CASA – High temperature Foam verification at Australian Airports 32
This Dubai aircraft fire has direct relevance Offshore, in Defence, Aviation, Shipping because there are
numerous helicopter flights transporting personnel to and from platforms, ships, Defence operations,
day and night, year-round, in often difficult weather conditions, which were also faced in Dubai. F3 use
places unacceptably increased risks to life safety, particularly in storms, hot summers, winters when
F3s may be very viscous, even semi-solid, so unable to be proportioned effectively. This could also
prevent any rotary or fixed wing aircraft fire from being controlled or extinguished, leading to
potentially catastrophic outcomes.

ii. Industrial fire comparison45-53

Submission to CASA – High temperature Foam verification at Australian Airports 33
There seems to be no evidence of F3 being successful in major incidents anywhere so far: just
two disasters, where significant adverse impacts were recorded following F3 usage. But this
seems to be ignored, rather than learning important lessons and informing important safety
changes.

This chemical factory fire was shocking in the socio-economic implications, severe health impacts to
firefighters, disastrous environmental outcomes, even when no PFAS containing foams were used. EPA
Victoria recorded PFAS levels 16 times above recreational quality limits in the nearby creek [river],
presumably from other PFAS-containing items consumed in the fire, as foam was confirmed by the Fire
Brigade as being only F3 used.

This is the reality of major fire outcomes where F3s are used and is a sobering ‘reality check’ of
potentially increasing catastrophic fires that could result from potentially misleading fire test
approvals, where inadequate safety factors, unrepresentative fuels and missing maximum
temperatures for operating conditions, could potentially be placing lives at unnecessarily increased
danger of harm, or even loss.

Submission to CASA – High temperature Foam verification at Australian Airports 34
Appendix B: Limited human health impacts of PFAS
1. The Federation of German Industries (BDI) issued a Chemicals
legislation position on PFAS restriction in Sep. 202161, representing 40
business sector Associations. They argued:
• Single PFAS grouping ignores diverse substances with different properties – all PFAS
are not equally persistent, nor equally mobile, nor bioaccumulative, …nor toxic.
• Virtually risk-free chemicals will be equated with SVHCs (Substances of Very High
Concern) with properties requiring regulation …ie. unfair.
• Restriction of PFAS as currently planned will be disproportionate and unworkable,
hindering achievement of both EU Green Deal and economic goals.
• Regulatory PFAS approach being planned is in contrast to generally accepted REACH
principles, such as that there should only be restrictions in the case of unmanageable
risks.

A lack of viable alternatives to PFAS substances means high socio-economic costs in trying to
replace them and placing lives in these six challenging sectors under increasing danger of
harm.

2. Orgalim in its Jan.2022 position paper on PFAS62 confirmed
• Orgalim represents 770,000 innovative technology Cos and is EU’s largest
manufacturing sector with 2,076 Billion Euro annual turnover:
• “A general PFAS ban contradicts REACH’s risk-based approach and would be
disproportionate.”
• It recognised that most PFAS are not classified as hazardous under the CLP regulation.
• “Restricting entire groups of substances to ‘essential uses’ would violate the principle
of proportionality.”
• ”Exemptions should therefore be granted where no appropriate substitute is
available.”

3. UK Royal Society of Chemistry (RSC) in Dec.2021 PFAS Position
Statement63 called for evidence-based risk assessments as the foundation of regulations.
Balancing precaution, risk and impacts is important, not indiscriminate action based on
persistence alone.
• “with current knowledge, we believe such indiscriminate action which could lead to
unnecessary damage to very beneficial industries and ban highly desirable and very
useful, some may say vital, products from the market. Such products could be
fundamental to quality and longevity of life and economic prosperity, and in reality
pose little or no risk to health and the environment”
• “As all PFAS are persistent, grouping approaches may be useful to identify the more
toxicologically benign and harmful classes of PFAS and assess bioaccumulation.”
• “Banning all PFAS on persistence alone would take little scientific resource but could
have massive unintended consequences for society with loss of important products
and disruption of vital processes.”

Submission to CASA – High temperature Foam verification at Australian Airports 35
Such risk assessments become critical when “SEAC notes that, based on info in Annex XV
report, the volumes of alternative surfactants needed in the foam product can be greater
than those of PFAS surfactants, and also the demanded volume of fluorine-free foam to
put down a fire may be greater (up to a double volume is reflected in the Annex to the
Annex XV report) than the corresponding volume of a PFAS-based foam.” and several
sectors are particularly constrained for space and extra volumes cannot be accommodated,
including offshore installations, defence and marine shipping.

4. University of Queensland’s (Dec.2020) Firefighter PFAS health
study64 found any adverse associations were small.
• This study covered 799 Aviation Rescue and Firefighting Services (ARFFS) firefighters
and vehicle technicians, across 27 Australian airports.
• Only 6 of 40 PFAAs (a PFAS subset) sampled from participant’s blood serum were
found in 90% of participant’s (therefore studied closely) ie. PFOA, PFNA, PFDA, PFHxS,
PFHpS & PFOS - all legacy long-chain C8-PFAS, already restricted from use in EU, and
no longer manufactured outside China (and possibly Russia).
• Maximum 95th percentile blood serum levels recorded were:
• PFOS 80µg/L or parts per billion (ppb)
• PFHxS 45ppb
• PFOA 3.5ppb.
• Lower levels were found for PFUnDA, PFHpA and PFBS in 30%, 29% and
16% participant’s serum, respectively.
• Remaining PFAAs were either not detected (including PFHxA, PFBA, 10:2, 8:2, 6:2 and
4:2 FTS) or below 15% participants, justifying no further study,
• Participants starting work pre-2005 had higher PFOS, PFHxS and PFHpS levels (as
expected) than Australia’s general population, strongly correlated with pre-2005
LightwaterÔ AFFF use.
• Those starting post-2005 had concentrations similar to the general population.
• All participants had "PFOA concentrations similar to general population, indicating no
increased exposure through occupational activities to this chemical".
• Comparisons of serum concentration for 130 ARFFS participants between previous
2013 and 2019 sampling, showed average decreases of PFOA 58%, PFHxS 42%, PFHpS
45% and PFOS 49%.
• “This suggests that substitution of 3M LightWater AFFF has been a successful measure
to reduce occupational exposure in participants who started working after 2005.”
• Minimal ongoing occupational PFAS exposure was evidenced from legacy C8
fluorotelomer AFFFs, in use until 2010.
• This longitudinal study60 confirmed no significant associations over time in
cholesterol (HDL, LDL) or urate (kidney) functions with PFAS concentrations.
• "Overall, the associations that were found were relatively small and did not result in
an increased risk of out-of-range (potentially abnormal) values across the serum
PFAA concentrations in this study."

Submission to CASA – High temperature Foam verification at Australian Airports 36
5. US Centre for Disease Control’s (CDC) 202165 – Early release of most
recent 2017-18 PFAS Blood Serum Survey of the US population also found:
• PFOS and PFOA blood levels had dropped by around 30% since the 2011-12 survey
results.
• PFHxA the main C6 –PFAS breakdown product was not detected in any age group or
any demographic across the whole US population, despite inevitable exposure from
the ubiquitous range of consumer items containing C6-PFAS from cosmetics and
medicines, computers and electronics, televisions, textiles, furnishings, mobile phones,
even dental floss.
• Presumably this is a result of the short average human half-life of 32 days for PFHxA,
excreted in urine. Very different behaviour when compared to human half-lives of
PFOS, PFOS and PFHxS averaging 5.4 years, 3.8 years and 8.5 years respectively, which
encourage elevated levels with repeated exposures.

6. Australian National University (Dec.2021) PFAS Human Health
Impacts – An Epidemiological Study66 examined three relatively high PFAS
exposure communities, resulting from extensive AFFF firefighting foam use and
contamination over decades from three nearby Australian Defence sites:
• Katherine (Northern Territory)
• Oakey (Queensland)
• Williamtown (New South Wales)

Comparisons of PFAS blood levels and health outcomes for people living and working in
these towns were made with three similar communities, without known environmental
PFAS contamination (comparison communities).
• Maximum blood serum levels reported included PFOS 470ng/ml or ppb (parts per
billion); PFHxS 523 ppb; PFOA 16.1ppb from over 2,500 participants
• “The [PFAS] health effects are small and unlikely to lead to poor health outcomes.”
Confirming lipids, cholesterol (HDL, LDL), kidney, liver and thyroid function biomarkers
did not change markedly in sensitivity analyses, with PFAS concentrations or
communities.
• “There was limited evidence to support a contributing link between PFAS exposure and
most adverse health outcomes included in the study. For most of these outcomes, the
differences in rates between PFAS affected and comparison communities were
relatively small. …In other similarly PFAS affected communities, the overall findings
relating to PFAS exposure are broadly applicable.”.
• More surprisingly “People living in all three PFAS affected communities, irrespective of
PFAS serum concentrations were more likely to have experienced psychological
distress than those who lived in comparison communities.” This psychological distress
presumably derived from anxiety, worry and fear their families may be harmed, based
on contaminated drinking water, ‘blighted’ property values and ‘media hype’.
• PFHxA and 6:2 FTS were confirmed as not detected in blood serum from any members
of exposed nor comparative communities.
• Concluding “The evidence for other adverse health outcomes was limited. For most
health outcomes studied, findings were consistent with previous studies that have not
identified contributing links between PFAS and health. …There was limited evidence to

Submission to CASA – High temperature Foam verification at Australian Airports 37
support a contributing link between PFAS and most adverse health outcomes included
in the study.”

7. Lacking Evidence of F3 success in major fire incidents
There is remarkably little evidence from large scale operational fires where F3 has been used,
to give us any assurances of effectiveness. What is evident is not very convincing and
highlights some disturbing traits and major safety concerns, of which SEAC and ICAO should
be aware:.

• Two claimed 2013 ‘F3 successes’ at London Heathrow were misleading67,68. Some major
airports have already transitioned to Fluorine Free Foams (F3s), fully accepting small scale
International Civil Aviation Organisation’s (ICAO) Level B, (rarely the tougher Level C)
approval and local testing as adequate indicators of likely F3 ‘success’,
• What happens if extensive evidence suggests such optimism may not eventuate?

• Air Accident Investigation report for
an Airbus A319 engine fire at LHR
(May2013)67 confirmed:
• The fire was controlled, almost
extinguished, by on-board fire
suppression systems, before
landing.
• Calculated fuel leakage rates
reportedly emptied the wing tank,
before landing, when some F3
was finally used.
• The small residual fire was quickly
extinguished using F3 prior to safe
passenger evacuation.
• Whilst this was a significant
incident, May temperatures are quite cool in UK, and it could hardly be claimed as a
challenging fire.

• Air Accident Investigation report of a further Boeing 787 fire at LHR (July 2013)68 occurred
when unpowered, unoccupied, and parked.
• Firefighters extinguished a small slow-burning composite material cabin roof fire
(likely from Li-ion battery fault), using a water hose-reel internally.
• A small amount of foam (F3) was used externally without impacting the fire
(probably unnecessarily and misleadingly also claimed an ‘F3 success’) as no fire
penetrated the fuselage.
• This could not be considered a serious incident, nor an example of operational
effectiveness of F3’s capability.
• Clean-up costs were apparently ‘zero’.
• Without direct proof of F3 efficacy in any major aircraft fires so far, concerns remain
and increase about the viability and functionality of these alternative foams under
challenging operational conditions.

Submission to CASA – High temperature Foam verification at Australian Airports 38
• Mounting comparative test evidence confirms inferior functionality, delivering
potentially increasing risk of catastrophic fires occurring during F3 use.
• There appear to be no reliable reports of F3 use on challenging major fires at airports
- except Dubai (see comments under 24 ii above), which was far from ‘successful’ –
most would consider it a ‘near-disaster’.
• SEAC understands60 that “Given the potential very high impacts of even a single
catastrophic fire on human health and the environment, the proportionality of the
proposal is uncertain if risks of such catastrophic fires are not kept as low as they are
currently. SEAC recommends in this context to adopt a no-regret strategy; that is, a
restriction option that remains justifiable whether catastrophic fires take place or
not.” The evidence presented should be sufficient to re-consider justifying a transition
period extension for aircraft movements in Civil Aviation, Offshore, Defence, Shipping
etc. to 10 years (with review).

8. Key questions should be answered to ensure F3 transition
continues existing safety levels, …otherwise just delay it…26,69
Foam users are being faced with increasingly complex choices, so it’s important to obtain clear written answers to key questions, while benchmarking F3 findings against existing fire system performance to avoid unintended consequences or common pitfalls, which could cause catastrophic fires.

These 15 key considerations69 should help maintain your facility’s current fire protection standards of life safety and critical assets, without becoming unnecessarily compromised.

1. Are your existing and proposed flammable liquids currently used/transported effectively
protected by F3? Standard test fuels are not always representative of your hazards,
especially with F3s so seek test data on the specific fuels you may be carrying like crude oil,
condensate, naphtha, gasoline blends, Jet A/A1 aviation fuel, etc. Research confirms most
F3s require higher application rates/longer operating times on such volatile fuels and
generally perform less well in seawater. This could mean even higher application rates,
greater concentrate storage and higher weight loadings.

2. If storing, handling or transporting crude oil, what F3 application rate reliably
extinguishes, before any boil-over may arise? Premium AR-AFFFs achieved this at 0.22 to
0.25 gpm/ft2 (9-10.25 L/min/m2) rates on crude oil. Firm F3 recommendations using
meaningful scale test data are needed for comparison. Expect higher AR-F3
recommendations than AR-AFFF.

3. Could longer extinguishment times increase fire spread and incident escalation risks?
Aiming to get flames out fast, protecting firefighters, crew and vessel while minimizing risk
of fire spread or incident escalation into new areas, is usually a key objective, which could
be more challenging using F3s. Check what F3 re-application frequency is necessary after
successful extinguishments or unignited fuel spillages? Faster foam blanket deterioration
where seawater and/or volatile fuels are used may require increased and/or longer
applications, which may vary with different fuels, potentially requiring extra F3 storage,
extra delivery devices, pipework etc.

Submission to CASA – High temperature Foam verification at Australian Airports 39
4. Entering F3 blankets during firefighting or rescue operations – is that still safe? Guidance in
this area is always difficult and F3s may vary with different fuels or delivery devices. NFPA-RF
Roadmap26 [paraphrased] cautions ‘you are transitioning to a less forgiving agent, solely
reliant on the foam blanket effectiveness from gentle application’. Pre-planning, training,
incident command practices and decision making all depend on critical knowledge for
firefighter safety and reducing risks.

5. Does a total system engineering approach (eg. UL/FM protocols) highlight any concerns?
Foam concentrates, proportioners, foam makers and the fuel being protected should all be
demonstrated effective together and listed through independent 3rd party approvals. NFPA-
RF Roadmap26 advises F3 systems “will need to be designed and installed within the listed
parameters in order to ensure a high probability of success during an actual event. …it
typically took two passes to extinguish all the fires [with F3] as opposed to one for AFFF.”
Check more viscous F3s still meet % proportioning rate accuracy requirements year-round,
while remaining effective with existing delivery devices, otherwise consider replacements.

6. Has a full cost-benefit analysis for your F3 transition been conducted? Keeping control of
expected costs, time-lines, out of service periods and fire performance helps ensure
existing safety protections are not unintentionally compromised, and all expected benefits
are delivered. Consider alternative solutions, including optimisation of existing C6-foam
containment and collection during major emergencies, which may prevent potentially
increased containment requirements for F3s.

7. Is your F3 compatible with other agents used on vessels? Dry Chemical often discharged
alongside, or above your foam, may cause partial or instant F3 collapse. Limited dry chemical
compatibility was found by FAA in six of nine leading F3s recently tested. One ignited
immediately.

8. Are current application rates and back-up stock levels still appropriate? F3 inventory levels
may need increasing if higher application rates or durations are required. This could require
extra storage and weight loadings. Check your Port Agents have usable compatible stocks,
plus quick re-stocking facilities following incidents, to minimise down-time.

9. What is your F3’s storage life and reliability record? Ensure 3 or 5-yr storage samples have
been tested to verify it passes, without gelling or separating, and still extinguishes volatile
fuels as effectively as when new? If not, have an aged F3 sample tested by an approved
independent laboratory to verify continued effectiveness on your flammable fuels,
avoiding performance deterioration over time. If using an AR-F3 also ensure long-term
stability on your specific polar-solvent fuels.

10. Does your F3 contain toxic, persistent, or harmful ingredients? NFPA-RF Roadmap14
cautions “It needs to be understood that the elimination of PFAS and/or fluorine from the
product does not address all the potential health and environmental hazards.” Do Safety
Data Sheets (SDS) provide aquatic toxicity (usually worse than AFFFs), human health data
and residual Fluorine/PFAS levels on the complete F3 mixture, not just key components?

Submission to CASA – High temperature Foam verification at Australian Airports 40
11. What level of existing system residual PFAS is ‘clean enough’? NFPA-RF Roadmap14
cautions “To date, there is no clear guidance for how clean final rinsate water must be to
satisfy local regulators (i.e., it is currently not mentioned or is undefined). Discussion has
been centered around trying to meet either the EPA drinking water advisory level for PFAS
(70 ppt), the 1 ppb total PFAS requirement in the NDAA for DoD foams, or the 1 ppm PFAS
that has become adopted by other industry standards (UL-162) and throughout Europe
(ECHA).” So define residual ppm/ppb PFAS levels of system rinse-water and F3 concentrate,
before installation. FAA reported (Jul.2022) five of seven leading F3 concentrates contained
high TOF (Total Organic Fluorine) levels of 10-87ppm (US EPA Method 537.1, 2020). Be sure
of your chosen laboratory’s ability to accurately test at detection levels necessary for
concentrate, foam solution and rinse-water.

12. Has alternative, equivalent fire cover been arranged during your F3 transition? Several
days or weeks may be required before system modifications, re-commissioning and re-
activation are complete and vessels/ships can be returned to service. Can discrete areas be
addressed or is a complete vessel foam system re-fit envisaged? Loading/unloading turn-
arounds, maintenance and port entry/exit/docking are often considered the most dangerous
times with contractors and unexpected problems often arising during such operations.

13. Has extended containment been considered? Potentially necessary if higher application
rates and/or more frequent F3 top-ups during incidents are likely, ensuring collection and
containment of firewater run-off also prevents potentially polluting overflows into port
environments. NFPA-RF recommends containment and collection of all F3 solutions with
safe disposal, according to applicable regulations.

14. F3 system commissioning recorded? Include video footage documenting your foam
system’s effectiveness and competency, before any future major incident occurs.

15. Do existing training programs need adjusting to ensure F3 is safely managed and
operated? NFPA-RF’s Road Map26 advises “the industry trend is towards collection and
disposal of F3s in the same manner as AFFF today, so unfortunately the ability to train with
these foams will have the same cost burden as the legacy AFFFs requiring special facilities
and waste containment/collection.” Proof of effectiveness and competency from F3
transitions, ensures your vessel’s adequate protection from future fire dangers. Training
with other groups and different Port Authorities ensures abilities and limitations of each
foam being used during a major fire emergency are understood …before fire strikes.

NFPA-RF’s ‘Road Map’ concludes26 “Ultimately, end users will need to design and install within the listed parameters in order to ensure a high probability of success during an actual event. … but a detailed evaluation must be completed prior to making that transition…” Adopting this ‘15 Question checklist69’ based on NFPA-RF’s Fire Service Transition Roadmap26 and expert’s guidance could achieve necessary assurances.
Obtaining satisfactory answers to all 15 key questions helps keep everyone safe, regulators satisfied, while retaining fire protection system objectives ie. keeping lives and vessels safe from unintended consequences, including risking life loss and/or critical facilities/vessel destruction. Doing so should enable
F3 transitions to move forward safely. Maintaining present proven C6-foam capabilities keeping everyone safe, until any unresolved answers are finalised, without exposing lives to increased danger requires a transition extension to 10 years (with review) in these six key challenging sectors as F3s are proven by

Submission to CASA – High temperature Foam verification at Australian Airports 41
this evidence presented as unable to provide equivalent functionality into the foreseeable future. It would be dangerous to encourage premature transitions, which could lead to unexpected catastrophic fires resulting.

References
1. Australian Bureau of Meteorology – Max. temperature data recorded at Australian Airports 2018 -2022
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Submission to CASA – High temperature Foam verification at Australian Airports 42
18. US Naval Research Laboratory (NRL – Hinnant, Ananth, Farley, Snow et al) – May 2020 – Extinction Performance
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AFFF%20with%20sea%20water%20represents%20a%20combined,comparison%20to%20that%20of%20pH
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Responders/Firefighting-Foams
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Free Foam (F3) Liquid Concentrate for Land-Based, Freshwater applications, 6Jan.2023
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Free Aircraft Fire Fighting Foam
https://www.faa.gov/airports/airport_safety/certalerts/part_139_certalert_23_01
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and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=11
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history/rocket-causes-deadly-fire-on-aircraft-carrier

Submission to CASA – High temperature Foam verification at Australian Airports 43
37. US Navy, Judge Advocate General’s Corps, 1968 – USS Forrestal Investigation by Judge Advocate General
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df
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http://navylive.dodlive.mil/2012/07/30/uss-forrestal-remembered-lessons-from-tragedy/
40. US Navy, 2017 – the Catastrophic Fire on Board USS Forrestal (CVA-59) https://www.history.navy.mil/browse-by-
topic/disasters-and-phenomena/forrestal-fire.html
41. Washington Post, 1988 – Sailor Killed in USS Nimitz flight deck fire
https://www.washingtonpost.com/archive/politics/1988/12/01/sailor-killed-in-accident-aboard-uss-
nimitz/cc47faac-35c8-470d-a11d-decb5ef8f458/
42. Associated Press news, 1988 – Gun mishap kills one aboard USS Nimitz
https://apnews.com/c04161c1723777b732c408cccfcd2763
43. United Press International, 1988 – Second Sailor dies from Nimitz blast
https://www.upi.com/Archives/1988/12/03/Second-sailor-dies-from-Nimitz-blast/6188597128400/
44. Transport Safety Investigation Bureau, Singapore Report AIB/AAI/CAS.122 dated 27Feb.2017
https://reports.aviation-safety.net/2016/20160627-0_B77W_9V-SWB.pdf
45. Institute of Fire Engineers – IFE Incident Directory – Albright and Wilson fire, Oct.1996
https://www.ife.org.uk/Firefighter-Safety-Incidents/1996-albright-and-wilson/38867
46. Avon Fire Brigade Incident report – Albright and Wilson Fire 3Oct.1996
https://www.ife.org.uk/write/MediaUploads/Incident%20directory/Albright%20and%20Wilson%20-
%201996/Incident_Report_Albright_and_Wilson_REDACTED.pdf
47. There is no official investigation report on the Footscray Fire yet available, it is still the subject of a Coronial
Investigation. Key reliable references follow: ABC News 31Aug2018 – Biggest fire in years continues to burn in
Melbourne’s western suburbs http://www.abc.net.au/news/2018-08-30/west-footscray-fire-sends-smoke-over-
melbourne-suburbs/10181410
48. The Age 31Aug2018 – Scores of dead fish, eels wash up after Melbourne factory fire
https://www.theage.com.au/national/victoria/scores-of-dead-fish-eels-wash-up-after-melbourne-factory-fire-
20180831-p500z5.html
49. EPA Victoria 1Sep2018 – Avoid Stony Creek water https://www.epa.vic.gov.au/about-us/news-centre/news-and-
updates/news/2018/september/01/avoid-stony-creek-water---epa
50. ABC News 13Sep2018 – Stony creek pollution from warehouse fire ‘as bad as it could be’ with no plan yet for
clean-up https://www.abc.net.au/news/2018-09-13/stony-creek-looks-dead-after-pollution-warehouse-
fire/10238724
51. EPA Victoria 19 Sep2018 – West Footscray-Tottenham fire - Water test results summary
https://www.epa.vic.gov.au/our-work/current-
issues/~/media/Images/Our%20work/Current%20issues/WestFootscray/West-Footscray-Fire--Water-test-
results-summary---19-September-2018.pdf
52. Melbourne Water 24Sep2018 – Stony Creek – Clean-up works https://www.melbournewater.com.au/what-we-
are-doing/works-and-projects-near-me/all-projects/stony-creek-clean-works
53. The Age 7Nov2019 – What happened to us in West Footscray?
https://www.theage.com.au/national/victoria/what-happened-to-us-in-west-footscray-firefighters-call-for-
answers-after-toxic-fire-20191106-p5382j.html
54. The Guardian, 19Jul.2022 – UK reaches hottest ever temperature as 40.2C recorded at Heathrow
https://www.theguardian.com/uk-news/2022/jul/19/uk-weather-record-hottest-day-ever-heatwave
55. New York Times, 10 Jan.2023 – The Last 8 Years Were Hottest on Record
https://www.nytimes.com/interractive/2023/climate/earth-hottest-years.html
56. UK Government 2015 – Air Accident Investigation Report on Accident to Airbus A319-131, G-EUOE London
Heathrow Airport, 24th May 2013, Report 1/2015 https://www.gov.uk/aaib-reports/aircraft-accident-report-1-
2015-airbus-a319-131-g-euoe-24-may-2013

Submission to CASA – High temperature Foam verification at Australian Airports 44
57. UK Government 2015 – Air Accident Investigation Report on Serious Incident to Boeing 787-8, ET-AOP London
Heathrow Airport, 12th July 2013, Report 2/2015 https://www.gov.uk/aaib-reports/aircraft-accident-report-2-
2015-boeing-b787-8-et-aop-12-july-2013
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https://www.icao.int/safety/GASP/Pages/Home.aspx
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Australia-SDS.pdf
60. European Chemicals Agency (ECHA), 2023 – SEAC Draft Opinion on Annex XV dossier proposing restrictions on
PFAS in firefighting foams. https://echa.europa.eu/documents/10162/e81126e5-1ea1-0118-b27c-86e8df4ff7b7
61. Federation of German Industries (BDI) Sep.2021 – EU Chemicals Legislation: Restriction of PFAS, Evaluation of
envisaged restriction procedure. Position paper https://english.bdi.eu/publication/news/eu-chemicals-strategy-
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papers/environment-orgalim-position-paper-restriction-pfas
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https://www.rsc.org/globalassets/22-new-perspectives/sustainability/a-chemicals-strategy-for-a-sustainable-
chemicals-revolution/pfas-policy-position-dec-2021.pdf
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Firefighting Service (ARFFS) Staff-2018/19, University of Queensland
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005%20Formatted_ASA%20Exposure%20Report_Final%281%29.pdf
65. US Center for Disease Control and Prevention (CDC), Feb.2021 – Early release: Per- and PolyFluorAlkyl Substances
(PFAS) Tables, 2011-2018 (Specifically 2017-2018 PFHxA Data set)
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66. Australian National University Dec. 2021 – PFAS Health Study on three PFAS impacted communities – Overall
Summary
https://www1.health.gov.au/internet/main/publishing.nsf/Content/44CB8059934695D6CA25802800245F06/$Fil
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2015-airbus-a319-131-g-euoe-24-may-2013
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Heathrow Airport, 12th July 2013, Report 2/2015 https://www.gov.uk/aaib-reports/aircraft-accident-report-2-
2015-boeing-b787-8-et-aop-12-july-2013
[redacted]
Catalyst Q1 Foam Edition p67-69, January 2023. https://www.joiff.com/the-catalyst/
70. US EPA, 2016 – PFOA Stewardship Program final report of 2015 goals met,
https://www.epa.gov/sites/production/files/2017-
02/documents/2016_pfoa_stewardship_summary_table_0.pdf
71. European Commission (EU), 2017 - COMMISSION REGULATION (EU) 2017/1000 of 13 June 2017 amending Annex
XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration,
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content/EN/TXT/PDF/?uri=CELEX:32017R1000&from=EN
72. Washington Post, 2 Aug. 2023 - These places baked the most in Earth’s hottest month on record
washingtonpost.com/weather/2023/08/02/July-hottest-month-global-temperatures/

Appendix C – About [redacted]

Submission to CASA – High temperature Foam verification at Australian Airports 45
[redacted] specialises in engaging with interested stakeholders as part of a
PFAS transition discussion. I am confident a consultative approach will produce better,
more broadly accepted, robust, meaningful, useful and implementable outcomes,
which also have an increased chance of being understood, respected and valued by
the wider firefighting and foam user community after your deliberations and
recommendations are concluded, because of this process and the broader
understanding achieved - which I hope will contribute to its final outcome.
[redacted] is nationally and internationally recognised for providing
Environmental and Fire Protection Consultancy Services, specialising in the area of firefighting foams, foam systems, their suitability, applications, system designs, environmental impacts and remediation.

It is run by [redacted]. [redacted] has over 30 year’s fire industry experience as an international specialist in Class B firefighting foams, fluorinated and fluorine free, their application and impacts, and design of foam systems, with expertise across product development, systems design, performance testing and evaluation, end-user sector requirements, environmental impacts, remediation and major incident emergency response. He has a wide range of clients including foam users, manufacturers, fire service Cos, Industry Associations and provides guidance through the minefield of complexity surrounding firefighting foams, to help achieve the best outcomes in decision making.

He was nominated as UK foam expert to the UK Government’s 2004 PFOS (PerFluoroOctanyl Sulphonate)
Strategy Review. He contributed major improvements to bunded areas, storage tank protection and LNG application additions as a member of the European CEN Standard Committee’s development of Fixed Foam
Firefighting Systems standard EN13565-2:2009.

An active member of Fire Protection Association Australia's Special Hazards Technical Advisory Committee, he provides technical advice to a diverse range of stakeholders to better protect Class B flammable liquids with potentially suitable C6 and PFAS-free (F3) alternatives. He also keeps abreast of PFAS impacted site remediation, health impacts and PFAS removal and destruction technologies. [redacted] is a UL162 Task Group member reviewing inclusion of F3s into this important fire test approval standard, while also invited as a
Technical Working Group member by Australia’s Civil Aviation Safety Authority (CASA) reviewing Aircraft
Rescue and Firefighting Service (ARFFS) regulations

[redacted] is therefore particularly well qualified to assist with informative aspects that may not have been previously considered. Also by explaining the relevance and full complexity of these firefighting foam performance and environmental issues, it could contribute towards improved decision-making.

These comments are intended to improve the understanding of strengths and weaknesses of both F3 and
C6 short-chain foam agents. Each has a part to play, but F3 is not currently capable of being relied upon as an ‘all-round’ firefighting agent for all major hazards being experienced in Europe, US, Asia and around the world. Realising the importance of fast, effective and reliable action to protect critical life safety, minimise incident escalation, protect critical assets while also minimising the overall environmental and societal impacts of the whole incident’s assessment is a challenge beyond the current capability of F3s alone. It is therefore important that proven effective agents are used to reduce life safety dangers for emergency responders, casualties, workforces, travelling public, aircraft and airports, offshore platforms, ships,

Submission to CASA – High temperature Foam verification at Australian Airports 46
industrial operations, defence facilities, remote bases and other restricted areas, plus any nearby communities and society in general, so that lives are saved, damage minimised to critical infrastructure and adverse environmental impacts reduced as far as practically possible, into the future.

v

Submission to CASA – High temperature Foam verification at Australian Airports 47