FOAM WITHDRAW RAISES QUESTIONS
A recent announcement by 3M has raised a number of questions about the health safety of AFFF foam concentrates. This page is an attempt to communicate on the issues raised and to begin to shed light on the results.
Foam concentrates are an unusual fire protection measure since the foam is not approved by UL, only the device or system in which it will be used is tested and listed. While foam manufacturers and fire fighters have always known that foam concentrates of the same type can be mixed in an emergency, the same is not true for foam concentrates in fire trucks, foam concentrate tanks and systems. Claims for expanded markets by foam manufacturers first released after the 3M announcement are not accurate since many devices are not cross listed for other concentrates by UL. A delay is expected in getting all equipment tested and listed by UL which will certainly heat up the foam industry for the next few years.
The subject is addressed in the following articles:
3 M WITHDRAWS AFFF FOAM FROM MARKET
opinion commentary by Jim Devonshire
THE ANNOUNCEMENT BY 3M by Jim Devonshire
3 M WITHDRAWS AFFF FOAM FROM MARKET
Excerpted from Business Week article, authored by Joseph Weber.
Business Week in the June 5, 2000 edition contains a major article about the recent announcement by 3 M to stop the production of a stain repellant Scotchgard. There is a direct relationship between this decision and the withdrawal of Aqueous Film Forming Foam manufactured by the 3M Company. The withdrawal is due to the voluntary action taken by 3M to remove products from the market that contain perfluorooctane sulfonate (PFOS).
PFOS is evidently starting to appear in minute amounts in the blood drawn from people living all across the country. The company, according to Business Week, does not feel that there is any evidence that the chemical and products containing related chemicals are a danger to humans. On May 16, 2000 the company decided to phase out PFOS and products containing related chemicals.
PFOS is not on the list of environmentalists' list of the most toxic chemicals, but 3M has decided not to wait for additional scientific evidence that the chemicals are toxic. The chemicals are used for coating of paper and textiles for goods that Business Week reports are used for pet-food bags, candy wrappers, carpeting and 3M brand Light Water, an AFFF. The first signs of trouble began in 1976 when a study determined that organic fluorides, known as POSF, were showing up in tiny quantities in human blood. Since the study was focused on the effects of water fluoridation and POSF was not the result of water treatment chemicals, the investigator Dr. Donald Taves from the University of Rochester was unable to determine how it got into the blood stream as well as it effects.
Business Week reports that the indication of the chemicals in the blood stream was taken seriously at 3 M which quickly launched programs to test employees at plants in Minn, Alabama, and Belgium to see if fluorine exposure were high. The found that workers blood was registering higher than the general population, medical evidence suggested that the higher levels posed no problem. The same results were found in the deaths of former employees or living workers.
POES a 3 M product used in AFFF fire-fighting foam is also produced in animals and humans, when certain precursor chemicals get into the cells. The precursors are part of the chemical makeup of Scotchgard fabric protector and are valued precisely for their hardiness. The repel water and oil like nothing else, making them potent stain-resisters.
During the 1980's, testing continued and grew more sophisticated in the early 1990's. Indications were that all test results were showing the chemicals clear of any problems. In 1997 the introduction of new detection techniques changed everything. New tests showed these chemicals in levels as low as 0.5 parts per million. This level is equated by 3 M scientists as being like 50 seconds in 32 years.
New tests of samples of blood from 18 blood banks along with samples from Europe and Asia were conducted. Stored, old samples of blood from Korean War veterans found that only the Korean War veterans' blood was free of contamination since it predated the Scotchgard material.
Kept up to date by 3 M EPA officials were particularly concerned by the persistence of PFOS. This chemical is so hardy it is not known if will break down and it accumulates in the tissue of humans and animals.
3M was reluctant to conclude to withdraw these chemicals which are valued for their ability to repel water or oil. All data on health pointed toward no health effect, William E. Coyne, senior vice-president for Research and Development states in the Business Week article. A further study on rats, monkey and other animals found that PFOS was detected in samples of animal tissue from all parts of the world. The chemical was found in numerous locations including in flesh-eating birds in the Pacific Ocean and the Baltic regions.
Further results of tests of animals found that heavy doses of PFOS (10,000 to 100,000 times likely human exposure) resulted in heavy rat offspring mortality, often in days after birth. Monkeys that were heavily doses also died. When reported to EPA, the seriousness of the results resulted in intensive review by EPA. While EPA has yet to ban the chemicals, the writing was on the wall according to one EPA official.
While the discontinuance of PFOS chemicals is targeted for year end, continuance of fire fighting foam may take longer.
Another view and comment is provided by an industry insider, Jim Devonshire in the following article proposed for publication in Europe later this year---
Editors note: the following commentary and opinion is offered here for discussion and informational purposes. The following is the personal opinion of Mr. Devonshire and is reprinted for purposes of providing information to our web-site readers.
by Jim Devonshire
We are confident that we already have the new replacement generation of fire fighting foam concentrates to replace the 3M foam concentrates that will be withdrawn shortly. We are producing a new very powerful fire fighting foam concentrate that is glycol-ether free and thus considered "Earth-Friendly". Even though we have only been producing foam concentrates for a short time, we have already realized tremendous success in municipal and industrial fire departments, both in the U.S. and overseas with a number of written testimonials from people who have used our products on "real" fires.
Our manufacturing capacity at the Buckeye plant in Kings Mountain, NC plant exceeds 20,000 gallons (75,000litres) every 3 – 4 hours. There is no doubt in my mind that we can meet any and I mean any requirement for synthetic foam concentrates placed upon us. We likely have more manufacturing capacity than the industry really needs, but in setting up a new plant, our president decided to build the infrastructure to properly go after the business, even before 3M made this announcement.
We have had brief discussions with 3M concerning the potential replacement of their products in the event of, for example a foam system discharge and will be looking very seriously into providing their customers a U.L. (Underwriters Laboratories) cross listing for their current hardware and the Buckeye Foam Concentrates.
Being new to the foam business, we do not carry any adverse baggage. 3M has always taken a position, sometimes in writing, that their products are not compatible in storage with products of other manufacturers. Fortunately for Buckeye, we were not included in this list. We are confident that the new range of Buckeye Foam Products, once tested in accordance with, for example the U.L. protocol will be a drop-in replacement for the 3M foam concentrates.
Buckeye Fire Equipment Company intends to be a major participant in the foam business worldwide. We have the resources and backing to support a major thrust in this direction, we intend to be a market leader in short order.
by Jim Devonshire
I never thought that, in my lifetime, I would hear these words;
"3M makes a planned exit from the A.F.F.F. market place".
The announcement by 3M to discontinue a $330MM Scotchgard™ business came as a surprise to everybody. Even as I prepare this article, I do not believe that the effect of this decision has been fully realized.
Furthermore, after the initial announcement, additional communication from 3M has been minimal, perhaps because they do not know what direction they should pursue, or perhaps one could speculate that they have not really finished with the foam business? Indeed 3M are still offering their Class "A" S.F.F.F. (Structural Fire Fighting Foam). It is perhaps not well known, but 3M had been working on a new fire fighting foam concentrate line, just before the announcement about Scotchgard™ was made. As you might expect, this position affects a great number of people employed at 3M and 3M customers who have come to rely on these products in their day-to-day existence. People have asked, why don’t they (3M) reformulate their products. Well, it is not that easy, understand that the A.F.F.F. product line uses excess raw materials, or by-products produced from another process, so reformulating would mean a completely new product line, which defeats the purpose of using this excess capacity already available within 3M.
There are some reports that 3M developed the A.F.F.F. concentrates and the AR-A.F.F.F. concentrates and revolutionized the foam business. What they actually did, was to take a good product, developed by a number of different organizations or companies to market. Keep the following facts in mind:
1). The original concept for A.F.F.F. concentrate dates back to 1962 at the U.S. Naval Research Laboratory in Washington, D.C. The actual development of the product is credited to a number of people who worked at the N.R.L. including R. L. Tuve, H. B. Peterson, R. R. Neil and the "Father" of the A.F.F.F. concentrates E. J. Jablonski who is also credited with the term "Light Water™". There is an N.R.L Report, " A New Vapor-Securing Agent for Flammable Liquid Fire Extinguishing" dated March 13, 1964 that is worth reading. I "lucked out" a number of years ago and met Mr. Jablonski, who was a very unassuming individual and a credit to the profession.
[ Editors note- Your editor was lucky enough to be present during some of the early tests of "Light Water" at NRL in the early 60's and was acquainted with Dr. Tuve and Jake Jablonski who was a revolutionary fire protection researcher - what has been done since? Most documents of the time credit Dr. Tuve as the inventor of AFFF and the developer of the concept of Twin Agent attack using AFFF twined with potassium dry chemical common to air craft fire fighting. See Principles of Fire Protection Chemistry by R. L. Tuve, 1976, NFPA for further details.]
2). 3M has also been credited with developing the alcohol resistant A.F.F.F. concentrates, (AR-A.F.F.F.), or the alcohol type concentrate (ATC). In fact, National Foam first developed the AR-A.F.F.F. concentrate for commercial use and sold the rights to other manufacturers, as it turns out for a song, in comparison to their use today. 3M should be credited for taking a tremendous concept and using the 3M marketing machine to get this product into the hands of the real users. In effect, 3M changed a "world-wide" protein-based foam market into a synthetic foam market place, almost single-handedly, after all, that’s all they made.
So, credit, where credits are due.
Back to the problem, after all of this, why did 3M take the decision to pull out of this business? This article will concentrate only on the foam business developed by 3M, which represents less than 10% of the value placed on the Scotchgard™ product line. In effect, 3M announced that it would voluntarily phase out a product line, (Scotchgard™), that contains a persistent bioaccumulative and toxic (PBT) pollutant. That they would find a more environmentally preferable substitute for the perfluorooctanyl sulfonate (PFOS) chemistry used for the manufacture of this product line, which includes the A.F.F.F. concentrates used for fire fighting. The data provided by 3M indicates that these chemicals are very persistent in the environment and have a tendency to accumulate in human and animal tissue to where a potential risk to human health exists over the long term. Initial reports indicated that this phase out would occur by the end of 2000, but more recent indications are that production may continue into 2002.
As early as 1986 it was discovered that people had "fluorocarbons" (perfluorinated organic sulfur) in their bloodstreams. Initially the results of the tests were confusing, early reports or theories were that perhaps toothpaste or fluorinated water was the source. However, the characteristics of the fluorocarbon found in the bloodstreams of these people was slightly different to those of toothpaste & water. Although early suspicions were that the source was in fact a 3M material, the test apparatus back then was perhaps not sophisticated enough to differentiate the potential sources. However, in the late ‘90’s further testing confirmed that in fact the 3M fluorochemicals were present in almost 100% of the world’s population, (that’s you and me). The fact that it is present does not necessarily mean it is harmful. Testing of 3M employees working at the plant manufacturing level showed measurements of fluorocarbons at about 100 times higher than that of the average person. Again, there appears to be no ill effects when the fluorochemicals are retained in the bloodstream.
The fact that 3M has decided, at least as of this writing, not to recall all of the foam concentrates currently deployed in the field, probably indicates that there are no immediate health concerns.
Does the problem of persistent chemicals in the bloodstream affect other manufacturers of A.F.F.F. concentrates? The answer as best as we can tell from the raw material suppliers, such as Elf ATO-Chem and Ciba Geigy, at this time, is NO!
It would appear that it is the method of manufacturing the 3M fluorochemical that differentiates it from other fluorochemicals. There are two different processes involved; 3M uses an electrofluorination process, which uses an organic sulfur as the raw material, while the other manufacturers use a telomerisation process, which involves a procedure using tetrafluoroethylene (TFE) as the raw material. It would appear that while the 3M fluorochemical is retained in the bloodstream, other manufacturers fluorochemicals are expelled through the tissue walls and out of the lungs, through the normal breathing process.
Over the past few weeks, many people have asked me many questions about the 3M position. My observations are that it is important to read the press release and note the actual content; this is a planned exit by a business group from an established business over the next 1 – 2 years. This is not an immediate exit from the business and other A.F.F.F. concentrate manufacturers will likely not see an immediate and massive gain in market dollars. In other words, 3M have indicated that they will continue to provide A.F.F.F. concentrates, in particular the 3%/6% AR-A.F.F.F. concentrates and the MIL-SPEC A.F.F.F. concentrates, through 2002. If you were to call 3M today, I am fairly certain that they could deliver any amount of A.F.F.F. concentrate that you may need!
The interesting thing about this whole process is that asking one question leads to another and the tentacles spread. For example, the withdrawal of 3M from this business is "blamed" on the fact that a fluorocarbon is found in the bloodstreams of employees. Did you know that there is a synthetic blood, based on fluorocarbons that is used for example by diabetics as an aid in regulating blood sugar levels. So in fact, the medical community is injecting fluorocarbons into people, deliberately!
Then we hear that testing of the 3M fluorochemicals resulted in a 100% mortality rate in laboratory test animals, which were rats. Left with this statement, everybody imagines the worst of horrors, particularly as many years ago, 3M filed a substantial risk notice of teratogens, which involves a material associated with birth defects. However, back to the mortality rate mentioned above; young rats are born with a certain amount of fat in their bodies, which they use as nourishment during the initial growth cycle. The introduction of the fluorochemical to the rat prohibits the fat from building up and the offspring die. The human body does not behave in the same manner and subsequently this is not a risk to people. This information can be taken out of context and another scare develops.
While this decision by 3M presents opportunities for the other A.F.F.F. manufacturers, it is not likely to be a major opportunity for any one manufacturer, is it likely to "triple" the sales of any one manufacturer. Without much thought, one can come up with at least a dozen A.F.F.F. manufacturers across the world, all of which have an opportunity to get some of this business. The available dollars will likely be split, perhaps evenly between the remaining suppliers. However, based on the information available and the reasons offered by 3M for their decision, it should make the users of these products more aware of the environmental concerns about using these products. Some years ago, DGBE (diethylene glycol butyl ether), a product used in the manufacture of most A.F.F.F. concentrates was placed on the Federal Register of hazardous air pollutants, which initiated some manufacturers to eliminate glycol ether from their formulations. Interestingly enough, not all manufacturers took this approach and it is easy to understand why, particularly when a reformulation would mean considerable development expense and then the tremendous costs for re-compliance with U.L. Listings. One of these manufacturers (those that did not remove the glycol ether) was subject to a report in November of 1999, when 4,500 gallons of A.F.F.F. spilled into the Des Plaines River as a result of an aircraft hangar foam system discharge. The Illinois EPA filed a notice of violation against the airline after the spill. Though initially the airline was told the material was non-toxic, the foam was found to contain glycol ether (DGBE), which is considered hazardous if consumed. Subsequently, I would suggest that users of foam concentrates support those manufacturers who took the time and trouble to reformulate and produce what is in essence an "Earth Friendly" foam concentrate.
There are some, particularly those in what might be called the "protein camp" who are saying, "see, we told you that stuff (A.F.F.F.) is bad for your health". What they fail to elaborate on is the fact that most of the protein foam concentrates contain heavy metals, which can also be harmful!
It is stated that the EPA (Environmental Protection Agency) mandated this move by 3M, but I tend to believe that this is a voluntary move by 3M for a number of other reasons we are not privy to at this time. Certainly the EPA has a say in instances where "hazardous" materials are involved, but this appears to be simply a business decision by 3M, based on what certain people at director level thought was best for 3M at this time. We must not loose sight of the fact that the foam business is relatively small, when compared not only to the specialty chemical division, but the overall 3M business of $16.0 billion. Checking the EPA web-site today showed ten (10) pages of announcements concerning environmental issues over pollution prevention. The 3M issue is just one very small part of a large subject matter.
The 3M Light Water™ (the premium A.F.F.F. line), trade name has been the subject of discussion and various people saying that they intend to buy the name and formulation. It should be pretty obvious that the formulation would have little value and could not used, if the raw materials to manufacture the product are being phased out. I would also be very surprised if 3M would even consider selling the Light Water™ name. I believe that it should be retired with full honors and deservedly so, since it has no doubt saved many lives over the past 40 years.
So, where are we? We have a decision by 3M to discontinue a product line that was perhaps at the end of its useful life span, particularly if one evaluates the 3M-business philosophy. We have issues concerning the products manufactured by 3M and their effects on the environment. With this in mind, we have the possibility that 3M having been exposed to this phase out, would like to see other A.F.F.F. manufacturers put under the microscope and be taken to task over this issue. In other words, put "reasonable doubt" in the EPA’s mind, or in the mind of some users to where they question the continued use of the A.F.F.F. product line, if we (3M) can’t have it, nobody else can!
We hear that other countries have already started to question the use of the fluorochemicals for fire fighting purposes, so watch this space for further developments.
Editors note: LCAI will continue to monitor the problems associated with change in foam concentrates and the impact on listings of devices, etc. Should any readers have any horror or tall tales to tell in this area please forward them for our consideration in this portion of the web-site.
Return to top