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A Timeline of AFFF Use and Regulatory Developments

firefighter turnout gear and respiratory masks

The aqueous film-forming foam (AFFF) timeline from when its use began until today reveals many failings, but recent developments offer hope to those affected. Because of their long history of using firefighting foam, innumerable military personnel and civilian firefighters have been—and still are—exposed to hazardous PFAS (per- and polyfluoroalkyl substances) in AFFF. Early indications of the foam’s toxicity didn’t inspire followup evaluations or industry studies, and instead of facing repercussions, manufacturers profited from decades of distribution.

AFFF Initial Development and Use

The development of aqueous film-forming foam in the 1960s was a revolutionary moment for firefighting. 3M was the lead chemical manufacturer assisting the U.S. Navy in creating a more effective fire suppressant. This need prompted by tragedy would ultimately lead to countless more deaths. 3M was one of the major producers of AFFF in the early years, becoming a central figure in many milestones, including:

  • Mid-1960s: 3M develops aqueous firefighting foam, a fluorinated surfactant
  • 1967: A catastrophic blaze on The Forrestal Navy vessel triggers the U.S. Navy to overhaul its firefighting protocols, deploying AFFF onboard ships and carriers at naval bases and air stations.
  • 1967: A MIL-SPEC (military specification) for AFFF liquid concentrate is established, opening the doors for other manufacturers to produce their own compounds.
  • 1973: Alcohol-resistant AFFF (AR-AFFF) is developed by National Foam, Inc., and contains the same fluorine compounds as traditional aqueous foam.
  • 1973: A study by the Air Force Weapons Laboratory to examine the disposal of AFFFs deems the “fluorocarbon surfactant… at best only partially biodegradable.” 
  • 1974: The safety of 3M’s Light Water AFFF brand comes into question and researchers discover aquatic animals experience acute toxicity after exposure.
  • 1976: Experimental AFFF formulations are explored in efforts to reduce the impact on the environment without diminishing firefighting power.
  • 1978: A U.S. Navy study on the impact of discharging AFFF wastewater into harbors indicates that “certain concentrations of AFFF are toxic to marine organisms.”

Decades of Widespread AFFF Use and Regulations

2000: The Naval Research Laboratory hosts the Department of Defense AFFF environmental meeting in which agencies are alerted that AFFF is bioaccumulative and toxic.

A Shift in AFFF Formulas

Prior to the new millennium, many manufacturers were making surfactants using components capable of degrading to long-chain PFAS, one of the most hazardous ‘forever’ chemicals. Knowledge of this changed people’s perception of legacy formulations of firefighting foam; support against its use grew, thanks to pressure from environmental groups and agencies, spurring on these important timeline events:

  • 2001: 3M begins to voluntarily phase out production of its legacy AFFF, acknowledging that this formula biodegrades to perfluorooctyl sulfonate (PFOS).
  • 2002: Modern AFFF, containing short-chain PFAS, becomes the dominant fluorinated foam.
  • 2002: Some of the first fluorine-free firefighting foams are launched as alternatives to AFFF.
  • 2004: The use of MIL-SPEC AFFF, the formula containing short-chain PFAS, is now required at all airports regulated by the Federal Aviation Administration (FAA).
  • 2010: 3M legacy AFFF is removed from the military’s qualified products list.
  • 2016: The Department of the Navy issues policies to limit releases of legacy AFFF for non-emergency operations. 
  • 2017: The military spec for AFFF (MIL-PRF-24385F) is amended to include maximum-allowable concentrations of PFOS and PFOA.

Modern-Era Limitations for AFFF Use and Production

The 2000s continued to swing opinions about PFAS and caused many to wonder whether using firefighting foams for emergency response is worth the impact AFFF makes on the environment and public health. State and local agencies began pressing for legislation and regulations to limit the use and distribution of PFAS-containing AFFF. Influential case studies on aqueous foams and recommendations from the Environmental Protection Agency (EPA) and other organizations brought about these early initiatives and regulations:

  • 2017: New York labels PFOS and PFOA as hazardous substances and mandates storage and registration requirements for Class B foams that contain at least 1% of these toxic chemicals.
  • 2018: The FAA Reauthorization Act states that aircraft manufacturers and airports shall not be required to use fluorinated chemicals to meet performance standards for airport rescue and firefighting.
  • 2018: Washington becomes the first U.S. state to ban the use of PFAS-containing Class B firefighting foams for training, and these may not be manufactured, sold, or distributed except where federally required. 
  • 2018: A take-back program in Washington is initiated and several states follow suit, giving fire departments access to proper disposal for legacy firefighting foams.
  • 2019: The National Defense Authorization Act (NDAA) passed by Congress requires all military sites to phase out the use of AFFF by October 1, 2024; training with fluorinated foam is prohibited.
  • 2020: The EPA puts a Significant New Use Rule (SNUR) into effect to prevent anyone from processing or manufacturing inactive PFAS, like those in legacy AFFF, without significant review. 
  • 2020: GreenScreen Certified Standards for Firefighting Foam are developed, allowing manufacturers to mark a qualifying firefighting product with a seal verifying the foam meets specific environmental and health criteria.
  • 2020: The first mandatory reporting regulations for AFFF discharges are established and continue on a state-by-state basis.

Recovery and Change: Where Is AFFF Regulation Today?

Even though the damaging effects of AFFF have been known for a half-century, real progress toward holding the manufacturers responsible has only just begun. Developments in AFFF litigations continue, giving those harmed by years of firefighting or military service renewed hope for change. While progress is promising, the failures show in the answers to these two questions:

Is AFFF still in use?

Yes, AFFF is still in use today, and even the legacy version of this firefighting foam has not yet been federally banned. As research agencies continue to define the potential risks of exposure to AFFF, state governments remain committed to eliminating this firefighting chemical by enacting local laws and regulations to restrict and eliminate its use.

Is AFFF a regulated substance?

AFFF is not a federally regulated substance. After decades on the commercial market, the production and sale of legacy AFFF are now outlawed, but its use is only restricted—not banned. Modern formulations of AFFF now undergo notification requirements for discharges, and disposal regulations have been mandated in many states; sweeping federal regulations for modern AFFF or mandates for fluorine-free concentrates have not been formally introduced.

Although change has been slow, recent years have been earmarked with milestones that those dealing with the fallout of exposure may find reassuring, most notably:

  • January 2023: The Department of Defense publishes a new fluorine-free foam military specification to comply with the requirements of the NDAA; manufacturers may submit PFAS-free agents for qualification.
  • As of May 2023: 32 states have proposed or adopted regulations on the use, sale, or manufacture of PFAS-containing firefighting foams. 
  • 2017 – Present Day: A wave of AFFF lawsuits that began in 2017 continues today, as a multidistrict litigation against the manufacturers of firefighting foams gains momentum.