Many of the bulk liquid products handled by ILTA member companies demand special precautions due to their flammable properties. While significant fire events at terminals are rare, responsible facility management demands that terminal operators maintain capabilities to respond quickly and effectively to fire events when they do occur. For decades, the tank storage industry has relied upon aqueous film-forming foams (AFFF) to protect communities, workers, commodities, and infrastructure from potentially dangerous fire hazards and environmental risks from fire events or spills, such as air pollution. The effectiveness of these foams was attributable to the unique characteristics of the perfluoroalkyl and polyfluoroalkyl substances (PFAS) they contained.
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ILTA firmly supports a safe, strategic, well-managed transition to fluorine-free, or PFAS-free, firefighting foams, while ensuring public and worker safety. We also recognise that significant barriers must be addressed before we can achieve a complete, industry-wide transition to safer alternatives.
Transitioning the liquid terminal industry’s existing stocks of firefighting foam to fluorine-free foams will require collaboration between regulators and industry stakeholders, including terminal owners and operators, firefighters, foam manufacturers, and disposal vendors. Alternative foams are not a drop-in substitute for AFFF. There are important research, development, deployment, training, disposal, and other activities that should be strategically thought through in developing a transition timeline. For example, to be effective, the replacement foams may require higher foam volumes, additional labour, and different application techniques and equipment. And we must allow time for coordination between these stakeholders for testing, training, equipment replacement, disposal, and other critical activities.
Terminal operators rely on the principle of mutual aid to ensure that they can provide adequate responses to incidents. During an event, neighbouring facilities may provide foam, equipment, or fire-fighting personnel. Importantly, due to the foam flow rates and potential contamination concerns, equipment prepared to deliver PFAS-containing foams cannot be used to deliver fluorine-free foams, and vice versa. For the largest fires, foam may be provided from other facilities across the region or even from across the country. This interdependence of terminals means more time is needed to eliminate PFAS-containing foams from our sector.
There are still challenges. We must ensure we do not introduce regrettable substitutes. Certification programmes, such as Green Screen, provide vital information about new alternatives. Moreover, there is no universally accepted method of safe disposal of PFAS-based firefighting foams. Incineration of PFAS chemicals is banned in several states, and a moratorium on PFAS incineration is in place at Department of Defense facilities. While new technologies to destroy PFAS in firefighting foams have recently entered the marketplace, more work is needed to validate these technologies for all legacy foams.
A coordinated transition to fluorine-free firefighting foams is essential to safe incident response across the liquid terminal industry. ILTA will continue working with a coalition of industry, firefighters, and environmental stakeholders to advocate for a national phase-out of fluorine-free foams on a practical, achievable timeline. It is vital that we avoid a piecemeal approach across different states.