The Environment Agency has issued the guidance below on compliance advice for PFOA Class B Firefighting Foams:
We are the Environment Agency. We monitor and enforce controls on certain chemicals – to protect the
environment and human health through exposure to the environment.
We are one of the enforcing authorities for the UK POPs Regulation, relating to controls on chemicals
known as Persistent Organic Pollutants (POPs).
The UK POPs Regulation bans the production, placing on the market and use of substances, mixtures and
articles containing Perfluorooctanoic acid (PFOA), its salts and PFOA related compounds.
PFOA, its salts and PFOA related compounds remain in the environment for very long periods of time.
They are toxic and gradually build up to harmful levels in living organisms.
PFOA, its salts and PFOA related compounds have previously been used as active ingredients in Class B
firefighting foams, particularly aqueous film forming foams, due to their surfactant properties. They may
also be present in foams as a contaminant.
There is currently an exemption in place for the use of PFOA, its salts and PFOA-related compounds in
fire-fighting foam for Class B fires already installed in systems, including both mobile and fixed systems.
This exemption is in place until 4 July 2025, subject to certain conditions being met.
What you need to do
You need to have confidence that you are compliant with the law.
To find out if the foam you hold contains PFOA, its salts and/or PFOA-related compounds, you can:
• Check the safety data sheet for the foam.
• Contact the supplier or manufacturer of the foam.
• Get the foam analysed by a suitable lab.
If you intend to use or have a stockpile of Class B foam already installed in systems which contains or may
contain PFOA, its salts and/or PFOA-related compounds, you have a legal obligation to meet the following
conditions:
• Holders of stockpiles greater than 50kg must notify the environment agency by completing a stockpile
notification form (webpage below) and sending to [email protected].
You must notify us as soon as possible if you hold a POPs stockpile.
• The fire-fighting foam shall not be used for training.
• The fire-fighting foam shall not be used for testing unless all releases are contained.
• As from 1 January 2023, the use of the fire-fighting foam shall only be allowed in sites where all
releases can be contained.
Further information on the use, storage, and disposal of POPs, including PFOA, can be found online at
www.gov.uk by searching “persistent organic pollutants”.
The POPs stockpile notification form can be found online at
www.gov.uk/government/publications/persistent-organic-pollutants-notifying-pops-stockpiles
We have provided supporting information from the UK POPs Regulation on the definition of substances
referred to as “PFOA, its salts and PFOA related compounds” and the concentration limits for unintentional
trace contamination with this communication.
We work with businesses to help them comply with environmental regulations. If you have any questions,
please do not hesitate to contact us at [email protected].
Definition of substances referred to as Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds as set out by the UK POPs Regulation
“Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds” means the following:
(i) perfluorooctanoic acid, including any of its branched isomers;
(ii) its salts;
(iii) PFOA-related compounds which, for the purposes of the Convention, are any substances that
degrade to PFOA, including any substances (including salts and polymers) having a linear or branched
perfluoroheptyl group with the moiety (C7F15)C as one of the structural elements.
The following compounds are not included as PFOA-related compounds:
(i) C8F17-X, where X = F, Cl, Br;
(ii) fluoropolymers that are covered by CF3[CF2]n-R’, where R’=any group, n> 16;
(iii) perfluoroalkyl carboxylic acids (including their salts, esters, halides and anhydrides) with ≥ 8
perfluorinated carbons;
(iv) perfluoroalkane sulfonic acids and perfluoro phosphonic acids (including their salts, esters, halides
and anhydrides) with ≥ 9 perfluorinated carbons;
(v) perfluorooctane sulfonic acid and its derivatives (PFOS), as listed in this Annex.
Unintentional trace contamination limits as set out by the UK POPs Regulation
1. For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of PFOA or any of its
salts equal to or below 0,025 mg/kg (0,0000025 % by weight) where they are present in substances,
mixtures or articles.
2. For the purposes of this entry, point (b) of Article 4(1) shall apply to concentrations of any individual
PFOA-related compound or a combination of PFOA-related compounds equal to or below 1 mg/kg (0,0001
% by weight) where they are present in substances, mixtures or articles
