It is surprising, despite, the publicity over recent years, that some shipyards have not understood the legislative changes and restrictions that have come into force regarding the use of Aqueous Film Forming Foam (AFFF) for firefighting onboard superyachts.
In order to put out flames containing flammable or combustible liquid fuel, (also known as Class B fires) aqueous film-forming foams (AFFF) are utilised. According to reports, 3M, a major chemical company, invented AFFF in the 1960s. Fire & Rescue services and organisations throughout the world have utilised AFFF as the "gold standard" for putting out liquid fuel fires for many years. Additionally, those fire & rescue services have routinely employed the chemical in training drills. The popularity of AFFF soon found its way into the maritime industry where it has remained as a primary extinguishing medium for many years.
This previously crucial and life-saving chemical is now seen by the world community as highly harmful and is being phased out globally. The foam's exceedingly poisonous "forever chemicals" are the reason for this.
The EU Regulations have, since July 4, 2020, required:
All existing stocks of AFFF containing PFOA installed in a premises may only be used for Class B fires (the burning of flammable liquids).
Use of AFFF containing PFOA is prohibited for training purposes.
Testing of equipment/systems of AFFF containing PFOA is only allowed if releases are contained and can be properly disposed of.
But since 01 January 2023 fire-fighting foam containing PFOAs have been prohibited if the foam cannot be contained or collected after a fire has been extinguished and after training or equipment testing. From July 2025, there will be a total ban on the use of fire-fighting foam containing PFOA.
Some shipyards and superyachts have already commenced the transition to 'Flourine-Free Foams' however we, at Maritime Aviation, cannot emphasise enough how crucial it is to verify that your current fire-fighting foam proportioning equipment is compatible with your new foam concentrate as more and more shipyards want fluorine-free foam concentrates for new build/refit yacht projects.
Fluorine free products may have visual characteristics that are strikingly similar to those of a typical AFFF or AR-AFFF, but in practice they may behave considerably differently. The transition from a C8 foam to a C6 foam or fluorine-free foam is not simple.
It is imperative that, BEFORE transition, you confirm that your system will perform as originally intended and that any engineering modifications have been made if necessary, whether it be a Water Turbine Foam Proportioner, Bladder tank, or other system. You can't just change from one to another, the same equipment needs to be professionally cleaned with any C8 foam concentrate and residual traces from tanks and equipment disposed of correctly prior to transition.
So NO, AFFF is not banned, but the EU and other countries that are signatories to the Stockholm Convention are now following restrictions on the use of PFOA (C8) based foams which DID limit the use to firefighting (no testing or training) until January 1st 2023 or until July 4th 2025, if ALL foam water run off can be contained. For example, if you are using a C8 AFFF concentrate through a Deck Integrated Firefighting System (DIFFS) on your heliport, then it you are now unable to use it unless you can capture all the run off!
If you have already transitioned to C6 AFFF or Fluorine Free foams and undertaken appropriate compatibility testing, then you are moving forward.
It is vital that shipyards, yacht management companies and Captains ensure that they fully understand this new 'global' legislation and take steps to ensure they are compliant. if you require further information then contact us at hello@maritimeaviation.com and we can connect you with our specialists.