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Safety Data Sheets (SDS) for AFFF have misled firefighters from the start, revealing warnings for eye and skin irritation, but not for serious health risks. An SDS, formerly MSDS (Material Safety Data Sheet), serves one purpose: to provide information about chemical hazards. Each Aqueous Film-Forming Foam (AFFF) manufacturer is responsible for the creation and distribution of SDS for end users. But rather than providing safety precautions and warnings, AFFF MSDS/SDS offered inaccurate, vague hazard warnings more about harboring trade secrets than protecting firefighters.
What Chemicals Require a Safety Data Sheet?
Any substance considered a hazardous chemical as defined by the Occupational Safety and Health Administration (OSHA) Hazard Communication Standards requires a Safety Data Sheet. ‘Hazards’ in this sense encompass any chemical that may cause any irritation, which could include window cleaner, detergents, and firefighting foam. Simply qualifying as a hazard does little to warn firefighters of the toxicity of the foam; the AFFF MSDS should have provided specific safety information relevant to the risks of exposure to AFFF.
Is AFFF a Hazardous Material?
Defining AFFF as hazardous varies by the agency, state, or manufacturer, because every entity offers a different response. OSHA considers AFFF a hazardous substance, and U.S. states like New York and Wisconsin have added aqueous foams to their statewide toxic substances lists, but the EPA lists foam suppressants only as a proposed hazard (and only formulations with PFOS and PFOA derivatives, at that).
The Troubling History of AFFF MSDS
Clarity issues on the Material Safety Data Sheets for AFFF are not new. Throughout the timeline of AFFF use and regulatory developments, these safety sheets have lacked appropriate health warnings and discharge precautions, and many included generalized information that gave users a false sense of security. The following are some of the misleading statements found on Safety Data Sheets for AFFF through years of use:
- Carcinogenicity: Not a carcinogen
- Ingestion: Undiluted FC-600 [Light Water] has an acute oral LD50 (rat) greater than 10 grams per kilogram of body weight. This classifies this product as being practically non-toxic orally.
- The toxicity of the product mixture has not been determined.
- The mixture consists of ingredient(s) of unknown toxicity.
When it suits them, manufacturers can provide a long list of studies pointing to the toxicity of legacy PFAS-derived suppressants, yet Safety Data Sheets for AFFF offer no indication any research was ever completed. The MSDS for AFFF that did list fluoroalkyl surfactant ingredients provided “none” as responses for the established exposure safety limits and offered no manufacturer-recommended guidelines—despite years of concerning data.
Despite voluminous studies confirming AFFF exposure is linked with cancer, contradictory warnings still appear, which only leave firefighters to wonder, Is AFFF a hazardous material? For example:
“This product contains one or more organic fluorochemicals that have the potential to be absorbed and remain in the body for long periods of time, either as the parent molecule or as metabolites, and may accumulate with repeated exposures. There are no known human health effects from anticipated exposure to these organic fluorochemicals when used as intended and instructed.
“The presence of organic fluorochemicals in the blood of the general population and subpopulations, such as workers, has been published dating back to the 1970s. 3M’s epidemiological study of its own workers indicates no adverse effects.” (Excerpt from FC-600F LIGHT WATER(TM) ATC(TM) AR-AFFF 3% OR 6% MSDS, published 02/10/2009)
The Current State of SDS for Aqueous Film-Forming Foam
Despite what manufacturers know about how AFFF is produced, disclosing the percentage of PFAS as an ingredient on Safety Data Sheets is still optional, and most producers are exercising their rights to remain silent.
The Conflict of Trade Secrets on AFFF SDS
According to Hazard Communication Standards, a manufacturer or importer may indicate on the SDS that the chemical identity or exact percentage of a hazardous ingredient is a “trade secret.” This allows AFFF SDS to note, “Exact concentration withheld as a trade secret,” instead of naming PFAS or any ingredients that may tip off users to its potential harm. Even when fluorinated surfactants, fluorosurfactants, or any term with “fluoro” is listed, the concentration is confidential, and the language provides no information to help firefighters gauge which additional protective measures to use.
Inaccurate Health Hazard Warnings on AFFF Safety Data Sheets
The Hazard Identification section on Safety Data Sheets for AFFF classifies the chemical and offers warning statements. The problem was that the sheets usually only addressed the eye and skin irritation hazards of firefighting foam. Many foam concentrates were listed as a 1, meaning “Slightly Hazardous,” just one mark above “Normal Material” and below “Hazardous,” “Extreme Danger”, and “Deadly.” More recent AFFF MSDS have now been upgraded to Extremely Dangerous.
The Future of Safety Data Sheets for Aqueous Film-Forming Foam
Manufacturers should be held accountable for the misinformation and inaccurate safety procedures in the Safety Data Sheets for AFFF. Hundreds of case studies for AFFF existed that highlighted the dangers of exposure, yet the SDS did not reflect any explicit warnings or strict precautionary statements. Manufacturers must improve the clarity of this documentation; SDS sections that indicate “no data available” or “this product has not been tested for toxicity” should instead provide useful data and preventative information. Since stockpiles of unused AFFF exist in barrels and tanks, updating and distributing these documents is a responsible step toward righting some of the past wrongs.
It has been documented that one well-known AFFF manufacturer provided an MSDS for its concentrate in 1997 that included a section entitled “Cancer,” warning readers about the possibility of tumors in animals, and citing studies performed in 1983 and 1993. The producer removed the section the same year and continued to sell the products for decades without adequate warnings. Manufacturers say the omittance was inconsequential, but if you ask any of the thousands who now qualify for an AFFF lawsuit, you’ll quickly learn how honest, adequate chemical documentation could have led to improved precautions and different outcomes.