
(Sviatlana Lazarenka/Getty Images)
In this op-ed, Jonathan Sharp with Environmental Litigation Group, PC, discusses the health impacts and alternatives to film-forming foam (AFFF).
Wisconsin is one of many states experiencing a public health crisis that is connected to decades of aqueous film-forming foam (AFFF) contamination. Aqueous film-forming foam is a Class B firefighting foam commonly used since the 1970s by fire departments to extinguish flammable liquid fires started by oil or gasoline, as well as in industrial facilities, military installations, and airports. AFFF contains per – and polyfluoroalkyl substances (PFAS) also known as “forever chemicals,” a category of synthetic chemicals composed of carbon-fluorine combination that is effective at combating fires but is also a very dangerous and toxic surfactant.
In 2022, the Environment Protection Agency (EPA) released data showing that almost 900 spills or uses of PFAS firefighting foams have entered local waterways. The use of AFFF has been restricted across the world since 2006 due to the water soluble components that remain permanently in the environment, contaminating wells and drinking water. Throughout the years, toxic AFFF used at military bases, airports, and firefighting facilities has infiltrated groundwater and soils. This contamination endangers the health and well-being of the military and civilian firefighters who have been consistently exposed to AFFF, as well as others consuming contaminated water.
Firefighters use AFFF used to extinguish oil and gas based fires, while being exposed to perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS). Until recently, the carcinogenic risks of these PFAS chemicals was almost entirely unknown by the firefighters who used these foams. Even today, these risks are not fully understood.
Regular exposure to AFFF through frequent (often daily) exposure is an occupational hazard. According to a number of studies, occupational users of AFFF are at an increased risk of developing a number of cancers, while cancer-related deaths are higher compared to the general population.
On April 10, 2024, the EPA announced new maximum levels for PFOA and PFOS of four parts per trillion. Continuing proactive actions should lead to more conscious decisions, and will significantly reduce PFAS exposure and prevent many PFAS-linked illnesses and deaths.
Choosing a fluorine-free firefighting foam alternative is a solution that many former PFAS foam users have begun to accept. But are these substitutes safe or just safer? The on-going process of transitioning to fluorine-free foams has been slow, especially amid the danger and concerns on the use of PFOA upon the environment and human health.
AFFF regulations in the state of Wisconsin
Among other states, Wisconsin has limited the use of AFFF, and implemented other measures that will significantly reduce PFAS contamination.
On September 1, 2020, Wisconsin began enforcing new restrictions that alleviate the release of PFAS-containing firefighting foam into surface water and sewage systems, taking proactive steps in preserving a balance between the environment and maintaining the health of Wisconsin’s citizens and firefighters.
According to the law, PFAS-containing foams are completely restricted for training exercises. The use of AFFF is only allowed in emergency actions as well as for trial objectives in facilities that can prevent the discharge of the toxic chemicals into the environment.
Additionally, the Wisconsin Department of Natural Resources addressed the public health danger of environmental contamination with an action plan. In 2020, the action plan included a collection and disposal program for PFAS-containing firefighting foam that removes old foam and remediates contaminated sites and water installations. The efforts conducted are a step forward in finding better solutions, but how about finding the right replacement?
Fluorine-Free Foams (F3): a safe alternative?
A fluorine-free foam is a firefighting foam that does not contain fluorine-based compounds such as PFAS. As effective as traditional firefighting foams may be in firefighting, they are dangerous due to their environmental persistence. In contrast fluorine-free foams are designed to fulfill firefighting necessities while being less damaging to the environment and less harmful to human health. The US Department of Defense is actively developing new foams that are free from PFAS. The program’s objectives are to remediate the damage done by AFFF contamination and avoid and reduce future exposure to the chemicals by military members, their families, and citizens.
Fluorine-free foam, a more conscious and viable alternative to AFFF, is developed with a combination of a highly effective phosphate betaine silicone surfactant (PPSS) and various hydrocarbon surfactants. Research and studies show incredible effectiveness in foams that mix sodium alpha-olefin sulfonate with PPSS. However, solvents and hydrocarbon surfactants that are present in fluorine-free foams are linked to central nervous system affects such as headache, dizziness, light‐headedness, progressing to unconsciousness, seizures, and may lead to death. Studies indicate that long-term exposure to solvents can cause neurodegenerative illnesses such as Alzheimer’s and Parkinson’s. Additionally, other studies indicate that long-term exposure to hydrocarbon surfactants can lead to hypotension, mental deterioration, respiratory failure, acute kidney injury and arrhythmia. Among the patients exposed to high volumes of surfactants, there were two deaths caused by refractory shock, metabolic acidosis and respiratory failure. This study exposes the impact of the exposure to surfactants for a long period of time can lead to skin irritation, eye irritation, allergic reaction such as coughing, swelling and endocrine disruption.
Some of the chemicals are not revealed and some products might include low levels of PFAS. To address the issue, Clean Production Action, a non-profit organization came forward and offered a solution. “GreenScreen Certified Standard for Firefighting Foams” is an eco-label certification program that guarantees fluorine-free alternatives do not contain any chemicals of concern.
The consequences of the exposure are well-known but to reduce the outcome for human health and for the environment, firefighters need to be trained and educated on how to use new foams effectively.
The decades of research and the proven pathology linked to PFAS exposure shows that something needs to be improved and changed and safer/healthier options need to be made available.

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