DOD Progress on AFFF Phase-out and Certification of Alternative Firefighting Foams

The revised version of the bipartisan 2023 National Defense Authorization Act, passed on December 15, includes a provision requiring an annual progress report on certifying PFAS-free replacements for AFFF. The DOD is already required to phase out all military use of AFFF by October 1, 2024.

Progress is being made on this transition as DOD officials are nearing final approval of purchasing requirements to phase out the use of PFAS-containing AFFF at military bases to meet a congressional deadline by January 31, 2023. The new MILSPECs would require contractors to have their products tested, qualified for purchase by DOD, and renewed every four years. Upon completion of this rule, efforts will be turned to the requirement to qualify fluorine-free foams by October 1, 2023.

However, external sources are casting doubt on DOD’s work to qualify PFAS-free foams. A new report from the Army Public Health Center (APHC) highlights uncertainties in the Pentagon’s work to find PFAS-free substitutes for AFFF. Uncertainties regarding human health, environmental health, and unknown product components underline APHC’s unresolved issues with the Pentagon’s lack of best practices and screening to determine the impacts of “top-performing” alternative foams. The report calls on DOD for further screening of alternative foams for exposure hazards, while cautioning against relying on the APHC’s results as a method of ranking PFAS-free alternatives.