Another facet of AFFF replacement concerns the current use of AFFF in fire-suppression operations by military services. The DoD continues to update concentration, treatment, and destruction protocols for AFFF as research progresses. Until there is an acceptable PFAS-free alternative, the Department is treating each use or release of AFFF as a spill event to limit releases to the environment. The Military Departments must also notify the OSD of emergency uses or accidental releases above certain levels within 24 hours. DoD provides notification to Congress for reportable releases and ensures consistent responses to accidental releases and spills on military installations and National Guard Facilities.
The Navy has initiated a prohibition on non-emergency use, including training and testing, and a restriction on AFFF use unless it is to address a fire emergency. That release is then considered a HAZMAT incident to effectively minimize environmental impact. The Navy has also implemented a replacement process which retires legacy AFFFs in favor of new, short-chain AFFFs containing significantly lower levels of PFASs. Facility designs and retrofits contain AFFF more effectively and human exposure is limited with Personal Protective Equipment.
Air Force limitations include completing the replacement of legacy AFFFs with short-chain AFFFs. The Air Force is also retrofitting equipment and facility systems to prevent AFFF discharge while testing and to integrate short-chain AFFF. Training exercises are limited to safely contained spaces to minimize environmental impact and any AFFF release requires immediate cleanup, with treatment equivalent to hazardous-material spills.
The Army is currently replacing legacy AFFF with short-chain AFFF in first responder and firefighting vehicles and has limited the use of AFFF to emergencies only. Vehicles which use AFFF are required to test without actual release of AFFF.