DOD’s Transition to PFAS-Free Alternatives to AFFFDOD’s Transition to PFAS-Free Alternatives to AFFF Findings The Department of Defense (DOD) has implemented measures to eliminate the use of aqueous film forming foam (AFFF) at its installations by 2024, with authorized exemptions possible through 2026. The military departments have established plans and costs for replacing AFFF at all mobile assets and facilities. DOD has developed specifications for fluorine-free foam as a PFAS-free alternative to meet fire suppression standards. Challenges However, the military departments have identified challenges that may affect the timeline and resources required to fully eliminate AFFF: * Compatibility issues with fluorine-free foams make them unsuitable for some fire suppression systems. * Significant financing needs ($2.1 billion estimated) are required for the transition. * U.S. Defense Department firefighters need training on the use of fluorine-free foams. Waiver Request In February 2024, DOD notified Congress of its intention to request two one-year waivers extending the use of AFFF until October 1, 2026. This is primarily due to the time needed to transition systems to fluorine-free alternatives without compromising missions or safety. Background DOD uses AFFF at its facilities to suppress flammable liquids. However, AFFF contains PFAS, which can have adverse health effects. Laws have been passed to restrict DOD’s use of PFAS-containing materials, including AFFF. Assessment This GAO assessment examined DOD’s actions to transition to PFAS-free alternatives to AFFF and the challenges it faces. It reviewed relevant statutes and examined DOD and military department documents and policies. Interviews were conducted with officials from various agencies responsible for implementing the AFFF transition.
What GAO Found
The Department of Defense (DOD) has taken steps to eliminate the use of aqueous film forming foam (AFFF), a product used to suppress flammable liquids, at its installations. AFFF contains per- and polyfluoroalkyl substances (PFAS), which can have adverse effects on human health, including effects on fetal development, the immune system, and the thyroid gland. PFAS can also cause liver damage and cancer. The National Defense Authorization Act for Fiscal Year 2020 required DOD, among other things, to phase out the use of AFFF at its installations by October 1, 2024, with exemptions possible through October 1, 2026, and an exemption for use aboard ships. The military departments have developed implementation plans, schedules, and costs for replacing AFFF at all land-based mobile assets and facilities worldwide. DOD has also developed specifications for the development of a fluorine-free foam that provides a PFAS-free alternative to meet DOD fire suppression performance standards.
Firefighters train to extinguish plane fires
The military departments have identified challenges that could impact the time and resources required to completely eliminate AFFF at DOD installations. For example:
- There are several compatibility issues with qualified fluorine-free foams that make them unsuitable as replacements for AFFF for certain tactical fire suppression systems. For example, they may not withstand certain temperatures or may not be mixed with water prior to use.
- There are significant financing needs for the transition from AFFF to a fluorine-free product, with initial estimates at over $2.1 billion.
- U.S. Department of Defense firefighters are not fully trained in the use of fluorine-free foams, which is different from the use of AFFF.
In February 2024, DOD notified Congress that it expects to submit the two authorized one-year waiver requests by the statutory deadline of October 1, 2024, extending the use of AFFF at DOD installations until October 1, 2026. The extensions are primarily due to the time required to transition systems from AFFF to fluorine-free alternatives without compromising missions or safety.
Why GAO Conducted This Study
DOD uses AFFF at approximately 1,500 facilities and more than 6,800 mobile assets worldwide to combat fires. Releases of AFFF to the environment, either through accidental releases or for fire training and emergency use, have resulted in PFAS detections in drinking water and groundwater at and around DOD facilities. In recent years, several laws have been passed to restrict DOD’s use of PFAS-containing materials, including AFFF.
GAO was asked to assess issues related to DOD’s transition to PFAS-free alternatives to AFFF. This included the extent to which DOD (1) has taken action to phase out the use of AFFF at DOD facilities and (2) has identified challenges that may impact its ability to meet regulatory deadlines for phasing out AFFF.
GAO reviewed relevant statutes and examined DOD and military department documents and policies regarding the use of and transition from AFFF. GAO also interviewed officials from the Office of the Assistant Secretary of Defense for Energy, Installations, and Environment; the military departments; and other agencies responsible for implementing the AFFF transition.
The Department of Defense provided technical comments on a draft of this report, which GAO has appropriately incorporated.
For further information, contact Alissa H. Czyz at (202) 512-3058 or [email protected].
