Incentives and Barriers to Adopting Fluorine-Free Foams (FFFs) in Fire Training Facilities: Results of the First North American Survey

Abstract

Fluorine-free foams (FFFs) have been introduced as alternatives to aqueous film-forming foams (AFFFs), which are based on per- and polyfluoroalkyl substances (PFASs). However, adoption of FFFs remains limited due to the lack of universal drop-in replacements and limited data on their health and environmental impacts. This study examined incentives and barriers to implementing FFFs in Fire Training Facilities (FTFs) to support the transition away from PFAS-based products. A survey was conducted from September 2022 to December 2023 across the U.S. and Canadian FTFs, including state-funded facilities, metropolitan fire departments, airports, military, and industrial brigades. Developed in partnership with fire service organizations, the survey assessed current foam use, motivations for transition, and associated challenges. Of all FTF training with Class B foams, 38% reported using FFF products. Primary incentives included environmental and health concerns, safety, and regulatory pressures. Key challenges were transition costs, training requirements, and uncertainties around disposal of foams. These findings highlight that while momentum toward FFF adoption is evident, ensuring products are genuinely PFAS-free and providing comprehensive training will be critical for effective, large-scale implementation. Fire training facilities can play a pivotal role in guiding this transition.

1. Introduction

Aqueous film-forming foams (AFFFs) are highly effective fire-extinguishing agents used to suppress Class B flammable and combustible liquid fires, such as those occurring at airports, on ships, in petrochemical facilities, and at large fuel storage tanks. Traditional AFFFs, also known as legacy foams, are based on long-chain per- and polyfluoroalkyl substance compounds (PFAS) such as perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). Their effective performance is attributed to the unique physicochemical properties of PFASs, which include both hydrophilic and hydrophobic characteristics, thermal resistance, and the ability to lower the surface tension of water. The foam extinguishes liquid fires by forming a film over the burning liquid, cooling the fuel, and separating flammable vapors from oxygen [1]. AFFF is primarily used by the military (29%), petrochemical industry (21%), petroleum refineries (20%), civil aviation (16%), and municipal fire departments (14%). The majority of AFFF usage (93%) occurs during training and testing at fire training facilities [2].

The use of AFFFs during fire training, system testing, and live fire responses is an important source of firefighters’ exposure to PFASs. Biomonitoring studies have consistently reported that firefighters who use AFFFs have higher serum levels of several PFASs compared to the general population [3,4,5,6,7]. Once in the bloodstream, many PFAS compounds persist for long periods, even for decades after a single exposure [8]. Studies have linked PFAS exposure to a number of adverse human health outcomes, including elevated blood lipids, endocrine disruption, liver damage, and increased risks of certain cancers [8,9]. In 2023, the International Agency for Research on Cancer (IARC) classified PFOA as carcinogenic to humans (Group 1) and PFOS as possibly carcinogenic to humans (Group 2B), based on mechanistic evidence and emerging links to testicular and kidney cancers. Research in the US and other countries has found that firefighters have an increased risk of cancer compared to the general population [10,11,12]. In 2022, IARC also classified firefighting as carcinogenic to humans (Group 1), with increased risks of mesothelioma, bladder cancer, and colon cancer, potentially associated with mixed occupational exposures including diesel exhaust, asbestos, flame retardants, solvents, and PFASs [13,14,15].

The historical use of AFFFs at military bases, airports, industrial plants, and firefighter training sites has contributed to widespread PFAS groundwater contamination, posing potential health risks among the general population in the U.S. [16]. PFAS contamination of drinking water has become a national issue that has prompted fast-paced policy changes [17]. In the mid-2000s, due to environmental and human health concerns, manufacturers began phasing out long-chain PFASs, introducing short-chain PFASs (with six or fewer fully fluorinated carbons in their alkyl chain) as substitutes. Firefighting foam formulated with short-chain PFASs (known as replacement foams within fire services) will hereafter be referred to as short-chain AFFFs (sAFFFs). The most common class of short-chain PFASs used was fluorotelomers produced by telomerization processes [1]. Two ultra-short-chain PFASs, perfluroroethane sulfonate (PFEtS-C2) and perfluroropropane sulfonate (PFPrS-C3), have been reported in the literature to be present in 3M AFFF products [18]. While the substitution of long-chain with short-chain PFASs was performed to address toxicity concerns, the mounting evidence on the toxicity of short-chain PFASs is prompting increased concerns from the use of these formulations [19].

Elimination of exposures at the source is the top priority measure of the hierarchy of controls for protecting workers and the public from hazardous exposures [20]. In the case of PFASs in firefighting foams, elimination of exposures can be achieved through substitution of traditional or legacy AFFFs with alternatives that do not contain PFASs. Substitution of legacy foams would simultaneously reduce firefighter PFAS exposures and address any potential future environmental contamination. PFAS-free AFFF alternatives, or fluorine-free foams (FFFs), are already available in the marketplace. The European Chemicals Agency identified at least 170 fluorine-free alternatives in use, produced globally by 38 different companies [2]. A general comparison between legacy AFFF and FFF formulations is presented in the Supplementary Material (Table S1). The new alternatives vary in their formulations; however, the exact chemical composition and whether the foams are truly fluorine free, as well as their toxicological profile, is often unknown because of the proprietary information restrictions (New York State Pollution Prevention Institute April 2019).

In practice, implementation of the new alternatives requires detailed alternatives assessment, a systematic approach to inform selection and substitution of safer chemicals and materials. Alternatives assessment which emerged as an approach in the early 1990s, is defined as “a process for identifying, comparing, and selecting safer alternatives to chemicals of concern on the basis of their hazards, comparative exposure, performance, and economic viability” [21,22]. The current alternatives assessment framework has been challenged in the case of AFFF substitutes due to (i) the time pressure to transition driven by rapidly changing regulations, and (ii) implementation of alternative products in practice without thorough alternatives assessments. The 2020 National Defense Authorization Act (NDAA) mandated the Department of Defense (DoD) to stop using AFFF at any of its military installations (except on shipboards) after October 2024, a deadline that has been extended to October 2026 [23]. As pressure for change increases and implementation progresses, it is critical to examine the incentives and barriers that influence the successful large-scale adoption of FFFs.

Our work aims to address knowledge gaps related to the implementation of FFF alternatives in fire training facilities (FTFs). We focused on FTFs due to their historical use of AFFFs for training exercises and PFAS environmental contamination near training sites. FTFs are also important to study, given that firefighter instructors are a higher-risk group due to the high frequency and duration of exposure to PFASs during training practices. Our objective was to determine the status of AFFF and FFF use in fire training facilities and identify the incentives and challenges associated with the implementation of FFFs at FTFs.

2. Methods

2.1. Survey Development

We developed a survey to collect information on the status of AFFF and FFF use in FTFs, the frequency of their application, product selection, best practices, challenges, and lessons learned from the current efforts and experiences in using FFF alternatives. It was designed to be completed by leadership staff at FTFs in the United States (US) and Canada. We focused on fire training facilities in both the US and Canada, which are very similar and closely aligned (e.g., North American Fire Training Directors), and thus, the reference throughout to ‘nationwide’ refers to both countries.

An initial literature review was conducted on available alternatives and the status of alternatives assessment for AFFF substitutes. The survey draft was developed based on a National Academy of Sciences report on the use of FFF alternatives at airports in North America [1] and the literature searches and was guided by the alternatives assessment framework [22]. The draft was reviewed by the fire service partners, including the Fire Protection Research Foundation (FPRF), International Public Safety Data Institute (IPSDI), and International Society of Fire Training Instructors (ISFSI). The revised draft was then sent to a Technical Advisory Panel (TAP) with representatives from fire service organizations nationwide organized by the FPRF to inform and guide survey development and implications of findings.

The final version of the survey consisted of three main parts: Part 1 included general information related to the FTFs including the number of training instructors and trainees, type and frequency of training activities, information about training with Class B foams and product procurement decisions. Part 2 collected information on the current use of legacy AFFFs and sAFFFs, including application methods, frequency of product use, and storage, containment, and disposal of the foam after its application. We further asked participants about the existing enforceable laws or regulations in their states/counties related to AFFFs, such as take-back programs, and restrictions on the use or disposal of AFFFs in the environment. Part 3 was designed to collect information on the use of FFF products, including procurement, storage, containment, and disposal. Part 3 also included a section on incentives and challenges associated with the use of FFFs that was designed based on the alternatives assessment framework, inclusive of (a) product availability and cost, (b) performance and feasibility; and (c) environmental and occupational health impact. The survey questions consisted of a combination of closed and open-ended responses, multiple choices, and a Likert-scale design. The original survey is available upon request from the corresponding author.

2.2. Survey Administration

The survey was administered using Research Electronic Data Capture (REDCap, version 15.0.3), a secure software application for building and managing online surveys, hosted by UMass Chan Medical School. We used a convenience sampling approach, targeting FTFs affiliated with national professional organizations, including the North America Fire Training Directors (NAFTD), IPSDI, and ISFSI. The survey was distributed among (a) state-funded fire training facilities; (b) metropolitan/municipal fire department training facilities; (c) private fire training facilities; (d) airport (ARFF) and military FTFs, as well as Industrial Fire Brigades at petrochemical facilities. Participation was voluntary and open to facilities that were members of or affiliated with these organizations. This approach ensured national coverage and access to key respondents representing leadership and instructors at fire training facilities across the US and Canada. A specific link connected to REDCap was sent by email to all FTF contacts who agreed to participate. The survey was actively distributed from September 2022 to December 2023.

2.3. Survey Data Analysis

Descriptive statistics included the number and percentage of responses from fire training facilities as well as the median and range number of firefighters trained annually at the facilities. Qualitative data from open-ended survey responses were analyzed through a combination of deductive and inductive coding to identify the incentives and challenges associated with FFF implementation. Geographic Information System (GIS) software (ArcGIS Pro, version 2.2.0) was employed to map the states with FTFs that responded to the survey and to identify those currently using FFFs. This study was deemed exempt from human subjects’ research review by the UMass Lowell Institutional Review Board (IRB).

3. Results

3.1. Characteristics of FTFs That Responded to the Survey

We received 101 survey responses from FTF representatives in the US and Canada, 3 of which were excluded from further analysis due to extensive missing data. Of the 98 total remaining, 94 were located in 31 different US states and 4 in Canada (Figure 1).

The highest number of FTFs that responded were from Michigan (n = 8), followed by Maine, Florida, Ohio, Wisconsin, and Illinois (n = 5). The majority of responding FTFs were associated with metropolitan/municipal fire department FTFs (40%), state-funded FTFs (25%), and county FTFs (10%). A smaller number of responses were from private FTFs (3%) and those housed in educational institutions such as community colleges and joint vocational schools (4%), as well as airports and military FTFs (2%) (Figure 2). About 15% of responses were from FTFs that included a combination of metropolitan/municipal fire departments, state-funded, county, military, airport, industrial, and private FTFs (Figure 2, pie chart).

The number of fire departments that trained at the FTFs ranged from 1 to 1000 (median 10;

Table 1. Characteristics of fire training facilities (FTFs) that participated in this study (n = 98).

Information Collected	Number of Responses n (%)	Median Number (Range)
Fire departments trained per year	96 (98.0%)	10 (1–1000)
Firefighters trained per year	96 (98.0%)	450 (7–50,000)
Instructors in FTF
Full-time instructors (30 h a week/more)	93 (94.9%)	4 (1–650)
Part-time instructors (less than 30 h)	85 (86.7%)	25 (1–900)
Volunteer instructors	79 (80.6%)	6 (1–100)
Types of fire departments trained *
Career Volunteer Combination career/volunteer Wildland/Wildland Urban Interface Airport Military Industrial Other	85 (86.7%) 62 (63.3%) 63 (64.3%) 16 (16.3%) 22 (22.4%) 22 (22.4%) 26 (26.5%) 11 (11.2%)
Type of training
Fixed-schedule training	6 (6.1%)
Non-fixed-schedule training	14 (14.3%)
Both fixed schedule and non-fixed schedule	79 (80.6%)

* includes multiple selections.

). The number of fire training instructors reported varied widely between FTFs, with the highest number of full-time instructors at 650 and part-time instructors at 900 (median 4 and 25, respectively). There was also a substantial variation in the number of firefighters trained by the FTFs, ranging from 7 to 50,000 trainees per year (median 450). The type of fire departments trained were primary structural career (86.7%), volunteer (63.3%), and combination departments (64.3%). Other fire departments, such as wildland, airport, military, and industrial brigade firefighters, accounted for ~16–26% of the use of the training facilities. Survey respondents included Training Officers, State Fire Training Directors, Fire Chiefs, and Fire Officers who were in charge of training (see Supplementary Material, Table S2).

3.2. Training with Class B Foams

Among the training facilities in the study, 57% (n = 56) had offered training with Class B foams, while 43% (n = 42) had never provided such training. Respondents indicated that not every FTF is trained with Class B foams because not all are licensed and trained to burn flammable liquids and because the foam is expensive to use for training, with the cost of disposal also being a limiting factor. Those that used Class B foams offered structural firefighter training on flammable liquids, flammable liquid fire suppression training, hazardous materials response training, and transportation incident response training. Also, testing of new equipment and techniques was performed using any foam available in inventory, including Class B foams.

Both fixed-schedule and non-fixed-schedule training were employed in the majority of the FTFs (Table 1), with a small percentage of those that offered only non-fixed-schedule training (14%) and fixed-schedule training (6%). The types of Class B foams ever used for training included AFFFs in 71% of sAFFFs in 73% of FTFs, and FFFs in 38% of FTFs. Other types of foams, such as protein foam, dish soap, and Class A foams, were reported less frequently than Class B foam training (see Supplementary Material, Table S3). Selection and procurement of the foams at each facility was performed by FTF employees with a variety of job titles, including directors, chiefs, training coordinators, and instructors (see Supplementary Material, Table S4).

3.3. Current Use of AFFFs and Short-Chain PFAS Replacement Foams (sAFFFs)

Legacy AFFFs: Among all facilities that had ever used Class B foams, only two facilities reported current use of legacy AFFFs; one was a metropolitan/municipal FTF and the other an airport FTF. Although the users were concerned about the health and safety, they indicated that they needed more information on AFFF hazards and firefighter exposure to PFASs to stop using AFFFs. About 22% of FTFs reported that they had stopped using AFFFs during 2000–2022, while the rest did not know when AFFF was last used; 90% of FTFs reported not having any AFFFs at their training facility. Information on the current inventory volume was not provided by most respondents; one facility reported 8000 gallons of AFFFs.

sAFFFs: Five FTFs indicated the “current” use of sAFFFs, with a median inventory of 130 gallons (range of 15–3000 gallons). These foams were used for airport fire suppression, training on extinguishing agents of apparatus, and inventory for field replacement and occasional training. Training was performed using mobile (fire apparatus-based) and portable (educator backpack) systems, while fixed system training was not reported. The most frequent fuels used for training were diesel, gasoline, and propane. The frequency of training ranged across facilities, but most facilities offered training once every 4–6 months (33.3%). The users of sAFFFs reported allowing the foam to infiltrate into soil during training, disposing of the foam through the municipal sewer system via collection in mobile tanks, or transporting it off-site for proper disposal. Those who reported not using sAFFFs had stopped using them sometime between 2015 and 2021.

3.4. Current Use of FFFs in Fire Training Facilities

Of all Class B foam users, 38% (n = 21) used FFFs at the time of the survey. These were located in 15 different US states and one Canadian province (Figure 1). Ohio had the highest number of responding FTFs that used FFFs (n = 3), followed by Massachusetts and Washington State (n = 2), while the rest of the states had one of the participating FTFs using FFFs. As shown in

Table 2. Adoption of fluorine-free foams (FFFs) among fire training facilities (FTFs) by facility type.

Type of Facility	FTFs That Ever Used Class B Foams n (% of Total)	FTFs Currently Using FFFs 2 n (% Among Class B Foam Users)
Metropolitan/municipal FTF (n = 39)	22 (56.4%)	12 (54.5%)
State FTF (n = 25)	13 (52.0%)	5 (38.5%)
Multiple FTF (n = 15)	10 (66.7%)	3 (30.0%)
All others 1 (n = 19)	11 (57.9%)	2 (9.1%)

¹ “All Others” include airport, military, private, and educational fire training facilities. ² Percentages for FFF adoption are calculated based on facilities that reported training with Class B foams.

, FFF adoption varied across facility types. Metropolitan and municipal FTFs had the highest adoption rate (54.5%), followed by state facilities (38.5%). Multiple-type and other facilities had lower adoption rates (30% and 9.1%, respectively). These differences likely reflect variability in institutional capacity and regulatory oversight. Larger, state-funded, or municipal facilities are more likely to receive technical guidance and funding support for PFAS-free transitions, whereas smaller and private facilities have limited budgets, a lack of training resources, and the absence of state mandates.

The majority of FTFs started using FFFs after 2018, although several facilities indicated that they had used FFFs a decade prior. The main product selection criteria were identified as the following: Green Screen certification (52%); preferences of the staff (43%); manufacturer representative recommendations (33%); and motivated by use at other FTFs (29%) (see Supplementary Material, Table S5). The disposal of FFFs was mostly performed by letting it filtrate into the soil (59%) or collecting and disposing of it as hazardous waste (41%). The list of FFF products reported and their chemical composition reported in the material safety datasheets is provided in Table S6 (see Supplementary Material).

Training with FFF utilized mostly diesel, gasoline, and propane fires and was performed with mobile and propane systems. The most frequently reported types of nozzles used were adjustable gallonage nozzles, air aspirating foam nozzles, and automatic or constant pressure nozzles. Almost all respondents reported the use of personal protective equipment (PPE) during training for both instructors and trainees, such as eye protection, work gloves, safety boots, fire retardant clothing, turnout gear, NFPA 1971 Structural/Proximity, PPE Ensemble, and NFPA 1981-compliant/self-contained breathing apparatus (SCBA).

Facilities that did not use FFF reported a wide range of reasons for avoiding these products, including “not sure which product to select”; “high cost associated with the change”; “not aware of FFF/PFAS-free firefighter foams”; “performance data is uncertain and/or lacking”; “human health and safety evidence is lacking”; “change requires education and training resources”; “FFF is not compatible with their equipment”; “waiting on the MilSpec to be announced”; “not mandated by regulations yet”; “dish soap works just as well and costs less”; and “never entertained the idea of FFF”.

3.5. Incentives and Challenges Associated with the Use of FFFs in Fire Training Facilities

The main challenges and incentives to substitution of AFFFs with FFFs, identified from the survey, were categorized into four main themes: cost, feasibility for training use, environmental, health and safety impact, and federal and state regulations (Figure 3).

3.5.1. Cost Associated with the Transition to FFFs

(a) Incentives: The major cost advantage associated with the use of the new FFF is the longer-term savings on the remediation costs. An important incentive was that the FFF products used were readily available for purchase in the US (for 90.5% of participants), which made it easy to procure the product. The majority of the FFF users (63%) indicated that the cost of the FFF products was comparable with the legacy AFFF, while only 32% indicated that the FFF product cost was much higher (in one case, the cost of FFFs was 25 times higher than the old AFFF). About 5.3% indicated a lower cost of FFF compared to AFFF. Although the survey data do not directly indicate any direct cost benefits, they indicate that the cost and availability of the products are not barriers to FFF implementation.

(b) Challenges: The cost associated with the implementation of the new FFF alternatives was the most frequently reported challenge. Important conversion costs reported include (1) cost of purchasing new equipment (25.0%); (2) cost of retrofitting the existing equipment (12.5%); (3) cost of cleaning the existing equipment (37.5%); as well as the cost of training to use the products, mechanic fees, and disposal of legacy foam inventory. The respondents indicated that AFFF is very costly to dispose of in states with no take-back programs and the disposal cost of old foam inventory should be budgeted for this as part of the switch.

3.5.2. Feasibility of FFF Use in Training

(a) Incentives: The majority of survey respondents found no specific advantage in using FFFs over AFFFs other than environmental and health and safety considerations (see next section). Only one survey respondent indicated that the FFF they used outperformed the legacy foams, and it can also be used for Class A fires. Overall, 90.5% of users recommended the FFF products they use for adaptation by other training facilities.

(b) Challenges: Changes in the training procedures when using FFFs were reported by 31% of respondents, indicating that the use of FFF products required changes in application approaches, such as a high air aspiration ratio and application of more foam to protect firefighters from flashback. About 19% of respondents indicated that the new FFF product was more viscous than AFFF and required a longer time to achieve the goal. Another important consideration was the need for a new training curriculum that addresses the application of FFFs (31.3%) and professional development to train the instructor cadre (18.8%). About 38% reported that the instructors were not trained prior to using FFFs. The majority of FTFs offered an initial training and periodic training for new recruits, firefighters, and instructors.

In the open responses, participants indicated that training is a critical part of transitioning to FFFs, emphasizing the need for a new foam training curriculum as an important step before purchasing the new equipment and responding to live fires. Changing the system that allows training with the new foam is important, but it requires cost-effective maintenance before it is fully operational. While smaller departments have given up training with flammable liquids and are using dish soap, they recognize that if they were to use actual flammable liquid firefighting, they would have to practice with the actual foams. The participants recognized that it has become difficult to train with Class B foams, and many facilities do not offer such training due to environmental concerns and the high cost of burning hydrocarbons in a training environment. This is not preferable for the small fire departments and even some state fire academies. An industrial FTF representative indicated that they provide training to any municipal fire department. On the other hand, one participant from the airport fire service indicated that the transition to FFFs would require retraining everyone on how firefighting is approached. He stated that “A lot of the safety factors that we counted on before are not going to be there, and the safety factor on how foams operate is a big concern to us”.

3.5.3. Environmental Health and Safety

(a) Incentives: The major reasons that motivated the current users of FFFs were the environmental, health, and safety benefits of PFAS-free foams (67% of FTFs). The participants explained that the implementation of FFFs at their facilities was performed to address environmental health and safety concerns and, in some cases, due to the newly set state regulations. A limited number reported having evidence that the products they are using are indeed PFAS-free, either from Green Screen certification, or the manufacturers provided PFAS-free testing results.

(b) Challenges: The main challenge raised was the disposal of the new FFF products. Only three participants noted state requirements on the storage and disposal of FFFs. Respondents emphasized the lack of direction on the proper disposal of the new FFFs as a primary concern. One of the concerns raised was the possibility of the mix-up between different foams, which has increased the cost of disposal.

Recalling the experience with the substitution of legacy AFFFs with short-chain replacement foams, one user explained that the substitution had been driven by manufacturers at that time, while the health hazards were not well understood on the ground. “We didn’t know what the problem was, but at that time, at the training facility, we were told to get rid of it, and we got rid of it almost overnight. I don’t think we were ever educated about the reason why we were getting rid of it. We never looked back until now.” As the awareness about PFASs increased and short-chain PFASs were recognized as “regrettable substitutes”, the fire service has become more cautious in the implementation of FFFs. “We are concerned that science is catching up with what science was before, where we thought we had all these great products, and now we see the hazards. We do not want in 2043 to have the same conversation, saying: oh, this is bad again”.

An important challenge raised was the issue of the disposal of the new foams. There are only three cases (3 out of 21) indicating current state requirements regarding the storage and disposal of FFFs. Participants reported a lack of direction on the proper disposal of the new foams. One stated that “With more direction in disposal practices, it would be easier to move away from existing short chain AFFF”.

3.6. Existing Enforceable Laws or Regulations

Enforceable regulations restricting AFFF use for any purpose in their states were reported by 43% of respondents (n = 24), while a slightly higher percentage (48%, n = 27) reported AFFF restrictions for training purposes (Figure 4). About 39% (n = 22) reported laws in their states that restrict the disposal of AFFFs to the environment, which were mostly initiated in 2022. Take-back or buyback programs for AFFFs existed in the states of 34% (n = 19) of respondents while the rest indicated a lack of such programs in their state (Figure 4). The take-back programs were mostly initiated in 2021–2022, except in one case, indicating the start of the program in 2018. In the states with active buyback programs, the disposal of legacy foams remains an important concern due to the high cost of disposal or uncertain directions about disposal methods. For example, Washington offers a free turn-in for the foam, while in Missouri, the cost of disposal is the responsibility of fire departments. The collection of old foam remains an issue at other facilities, which cannot find anyone to collect it due to environmental concerns. One respondent expressed his concern: “At the facility where I work, we currently have a large amount of old foam stored in totes and bins inside warehouses, classified as hazardous waste. However, we face a dilemma: what to do with it, since the foam cannot be incinerated. Figuring out how to dispose of the old foam is the biggest challenge at this point”.

4. Discussion

Replacing aqueous film-forming foams (AFFFs) with fluorine-free foams (FFFs) is a national priority to reduce PFAS contamination and protect firefighter health. Our survey of fire training facilities (FTFs) provides the first nationwide overview of current practices and transition challenges. As of late 2023, most of the FTFs responding to our survey had discontinued PFAS-based Class B foams, and approximately 38% reported adopting FFFs. Fire departments that still maintain inventories of legacy foams reported using them only for emergencies, not for training. The primary incentives for adopting FFFs include environmental and health considerations, safety concerns, and evolving regulations. However, the transition process is ongoing and accompanied by several challenges, such as higher costs, the need for updated training curricula in FTFs, and the absence of clear disposal guidelines for the new FFF products, as well as challenges associated in managing the disposal of legacy foams.

Transition costs were consistently cited, particularly expenses related to cleaning or retrofitting equipment and disposing of legacy foams. Importantly, the purchase price of FFF products themselves was not the primary concern. Instead, the disposal of legacy foams emerged as a major challenge. A recent report by the U.S. Government Accountability Office (GAO) for the Department of Defense estimated transition costs at USD 2.1 billion, encompassing training, system modifications, foam disposal, and procurement [23]. The magnitude of the transition costs underscores the need for coordinated policies and resources to support fire training facilities through the transition.

Concerns about environmental health and safety. Evidence of regrettable substitution was strongly voiced. Respondents recalled the rapid shift from long-chain AFFFs to short-chain PFAS foams in the 2000s, implemented with limited toxicological data and later recognized as hazardous. The participants voiced their incensed concern about another regrettable substitute with the new PFAS-free foams and the need for solid data on the health, safety, and environmental impact of the new products. Although Green Screen certification was reported as an important criterion for product selection, skepticism remains about whether all marketed FFF products are truly PFAS-free.

To ensure that FFFs do not become regrettable substitutes for AFFFs, systematic toxicological testing and long-term environmental monitoring are essential. We propose a tiered evaluation framework that includes (1) verification of PFAS-free status, using targeted PFAS analysis, untargeted PFAS screening, and total fluorine analysis; (2) testing of commercial FFF formulations under standardized fire-like conditions in controlled environmental chambers to assess thermal degradation behavior and emission profiles (e.g., gases, VOCs, SVOCs, aldehydes, and nanoparticles); and (3) toxicity screening, involving in vitro testing of FFF formulations and their degradation products, followed by in vivo evaluation of formulations or endpoints identified as potentially hazardous. As part of a FEMA-funded project, our group tested 22 commercially available FFF products and characterized their PFAS content and thermal degradation profiles. The results, currently in preparation for publication, demonstrate that FFF formulations vary widely in emission profiles, including the production of aldehydes, NOx, and SO₂, underscoring the importance of testing thermal degradation products [24]. These findings will inform sampling strategies for field investigations of PFAS exposure sources and real-world exposure assessments. Comparative exposure assessments between frequently used FFF formulations under representative training scenarios are needed to address current gaps in the alternatives assessment framework.

We identified a common misconception regarding Class A foams being viewed as PFAS-free alternatives to AFFFs. Many lists of “alternatives” include wetting agents, which are designed for Class A fires involving ordinary combustibles (e.g., wood, paper, coal) but are not suitable for Class B flammable liquid fires. The first Green Screen-certified firefighter foams, for example, included a wetting agent, illustrating how loosely the term “foam” is sometimes applied in the fire service. This ambiguity can create confusion between wetting agents and true fluorine-free foams (FFFs). Importantly, PFAS-free certified wetting agents should not be used for Class B fire suppression, and this distinction must be made clear to users during product selection.

Performance consideration was recognized as important. Prior research indicates that FFFs are not “drop-in” replacements and require technical adjustments to match AFFF’s extinguishing capacity, particularly in aviation fuel scenarios. Over the past few years, extensive research efforts have focused on the evaluation of the fire protection performance of FFF alternatives [25]. The work of the Fire Protection Research Foundation, focused on firefighting capabilities of Class B firefighting foams on fires involving hydrocarbon and alcohol-based fuels, concluded that end users will need to determine the specific parameters to ensure high performance during fire protection events [26]. In 2022, the FAA evaluated the performance of commercially available FFFs as potential replacements for AFFFs used at U.S. airports. The critical extinguishment performance of FFFs did not match AFFFs under aviation fuel fire scenarios, and it was influenced by the technique and application method. In one training center in our study, the technical performance of the foam was evaluated onsite and the users of FFFs were confident in the FFF products they selected. Although the foam performance was recognized as important, that did not dominate decision-making for training purposes among FTFs that participated.

Policy and regulatory implications emerged as a recurring theme. Respondents noted inconsistent state-level regulations and limited guidance on FFF disposal. The new DoD military specification (Milspec) for FFF from January 2023, for the first time, considers health and safety in addition to the technical performance of the foams [27]. The level of PFASs in the products that meet the specifications must not exceed 1 part per billion (ppb). The first DoD Qualified Products List (QPL) based on the new MilSpec was published in October 2023; at the time, we were wrapping up the survey [28]. Respondents at that time expressed uncertainty around the adoption of newly qualified MilSpec products. The wide range of products available in the market that have not been qualified by DoD highlights the importance of testing to ensure that these alternatives are effective, truly PFAS-free, and not regrettable substitutes.

From the eight FFF products reported from the participants, three are produced by the same manufacturers of the products in the QPL [28]. Our review of the safety datasheets revealed no presence of PFASs in the reported products (Table S6), although SDSs do not report concentrations at <1% in volume and sometimes do not disclose all information but indicate trade secrets. As research and development progress and the list of qualified products expands, product selection remains a critical component of the transition and should be emphasized in the training of dedicated personnel. In addition to the selection of products with the lowest hazard profiles, the long-term environmental and health monitoring of replacement foams are also needed to evaluate the new substitutes, as comparative exposure assessments are lacking in the existing alternatives assessment framework [1,29]

Approximately 82% of FTFs using FFFs were operating in states with active AFFF restrictions or take-back programs, whereas non-users were primarily based in states without such policies. Overall, larger metropolitan and state-funded facilities have advanced further in the transition to FFFs, while smaller or privately funded ones face greater financial and logistical barriers. Although based on a limited sample, these results underscore that regulatory pressure acts as a catalyst for FFF adoption by increasing institutional awareness, providing funding opportunities, and facilitating the safe disposal of legacy foams.

Training-related issues were also central. Respondents reported that FFF use often required different application techniques, higher foam volumes, and updated curricula. Instructors were not always adequately trained before FFF implementation, highlighting a pressing need for standardized educational resources. Facilities with strong infrastructure, such as industrial training centers, may be best positioned to pioneer safe implementation, but nationwide progress will require harmonized standards, disposal guidelines, and training curricula.

Trade-offs between motivators and challenges. The substitution of AFFFs with FFFs reflects an anticipated trade-off between environmental health and regulatory motivators and significant economic, performance, and operational challenges. Our results indicate that facilities are driven by growing concern over PFAS exposure, environmental contamination, and regulatory mandates. However, these expected benefits are offset by short-term costs associated with the disposal of legacy foams, equipment cleaning or retrofitting, and personnel retraining. Despite these expenses, the long-term environmental and health benefits, including avoided remediation costs associated with PFASs, reduced toxic tort liability, and regulatory compliance, can outweigh the initial investments. Furthermore, while FFF adoption may offer environmental and health advantages, it also requires substantial investment in updated training curricula, technical guidance, and operator competency to ensure reliable fire suppression outcomes. Without adequate training and system adjustments, the effectiveness and safety of FFFs during live fire exercises may be reduced despite their clear environmental and health benefits.

Strengths and limitations: Although the total number of responses (n = 101, with 98 valid responses) is relatively small, this is one of the most extensive datasets available to date on FFF adoption among FTFs in North America. Respondents represented 31 U.S. states and 4 Canadian provinces, including state-funded, metropolitan, county, industrial, and airport training facilities, providing broad geographic and organizational coverage. Because participation was voluntary and distributed through professional organizations, the sample may overrepresent larger or better-resourced facilities that are already engaged in PFAS-free initiatives and underrepresent smaller or rural FTFs not affiliated with these networks. Based on the NAFTD data, our sample captured 40% of state facilities from most U.S. regions, indicating reasonable geographic representativeness. However, caution should be used when generalizing these findings to other FTFs in the US. Survey responses were received from four of the ten Canadian provinces, which limits the generalizability of our findings across Canada and underscores the need for a dedicated, Canada-focused study. Additionally, because the survey was conducted prior to the release of the DoD QPL, the results may not reflect the most recent product adoptions.

5. Conclusions

The adoption of FFFs is advancing but remains uneven, depending on the resources available at each FTF. Among facilities that trained with Class B foams, over one-third reported the current use of FFFs, while a smaller proportion continued to use legacy AFFFs (3%) or sAFFFs (9%). The main incentives for adoption included environmental and health concerns (67%) and regulatory pressure (82%), while the primary challenge for most participants was the cost of transition. Facilities located in states with AFFF restrictions or take-back programs were more likely to have adopted FFFs than those without such regulations, underscoring the influence of policy support on implementation. Fire training facilities are uniquely positioned to lead this transition by piloting safer products, developing updated training curricula, and sharing best practices. Future efforts should focus on developing standardized training and performance evaluation protocols for FFFs, establishing long-term environmental and occupational monitoring programs, and conducting comparative exposure and cost–benefit analyses to inform procurement and policy decisions. Continued collaboration between regulators, researchers, and the fire service will be critical to ensure that this transition eliminates PFAS exposures without introducing new unintended risks.