Rhode Island is one of the states that has completely banned the use of Class-B aqueous film-forming foam (AFFF), a firefighting foam that contains high levels of per- and polyfluoroalkyl substances (PFAS). Class-B foams are designed to extinguish fuel fires from combustible and flammable liquids, such as gasoline, oil, and jet fuel. AFFF is the most commonly used class-B foam produced since the 1960s. It is highly effective, as it forms an aqueous film that quickly cuts off oxygen and extinguishes the fire. The primary concern with AFFF is that it contains fluorinated surfactants, which can contribute to the presence of PFAS, known for their persistence and potential adverse health effects.

Over the past couple of years, numerous scientific studies have demonstrated that PFAS are highly persistent once they enter the environment, primarily groundwater, and pose a significant risk to human health. Even the slightest exposure to them can cause various diseases, mainly cancer. Individuals most affected by exposure to PFAS are firefighters who have used AFFF formulations at military bases, commercial airports, and fire stations.

Due to concerns about PFAS, some municipal fire departments and major airports across the United States are switching to PFAS-free firefighting foam alternatives, with fluorine-free foams being the most viable solution. However, since there is no overarching federal regulation concerning the use of AFFF, states can adopt their own legal provisions and standards.

AFFF regulations in Rhode Island

Firefighters deployed to most military installations, such as the Coventry Training Site, have used AFFF for decades, which has resulted in adverse environmental and public health issues.

Beginning in January, Rhode Island state laws were enacted to regulate the use and disposal of AFFF by banning the manufacture, sale, and distribution of firefighting foams containing intentionally added PFAS, except in specific emergency situations or when required by federal law. Fire departments can still use AFFF when no other foam is suitable for a fire. Meanwhile, the law provides a limited exemption for terminal operators: they may apply for a one-year allowance to continue using PFAS-based foam, but only if they can prove that no viable alternative exists, disclose how much foam is in use, show progress toward a safer substitute, and ensure that every release is fully contained to prevent environmental contamination.

Additionally, manufacturers or anyone selling firefighting protective equipment must provide written notice to buyers, including local governments and state agencies, disclosing if the gear contains PFAS and explaining why these chemicals were added.

Still, the risk of PFAS contaminating Rhode Island’s groundwater during firefighting operations persists as long as AFFF is used. While fluorine-free foams are marketed as alternatives, state authorities note that further testing is necessary to understand their safety and environmental impacts fully.

Fluorine-free firefighting foam alternatives

Fluorine-free foams rely on a blanket of bubbles proven to be slightly less effective than AFFF’s film. While it requires more volume and specialized equipment to be effective, these foams are composed of low-impact substances and are almost entirely biodegradable. Fluorine-free foams are PFAS-free, but they still contain solvents and hydrocarbon surfactants that are toxic chemicals.

By 2019, more than 22 manufacturers worldwide had offered some 90 fluorine-free foams (F3) designed to comply with stringent safety and performance standards. Meanwhile, Cross Plains Solutions developed the first soy-based fire suppressant, which entered the commercial market due to its environmentally friendly nature.

While F3 eliminates the dangers of PFAS, some of its components may still contain chemicals and solvents that pose environmental and health threats. Research indicates that exposure to these compounds can have both immediate and long-term health consequences. Studies have documented effects ranging from endocrine disruption to neurotoxicity, highlighting the potential for severe physiological impacts. Conditions such as skin and eye irritation are also reported. Additionally, soy may cause allergic reactions in individuals with sensitivities to the said legume or its derivatives, and its long-term use remains uncertain.

Beyond human health, these substances also pose clear environmental risks, contributing to toxicity in both aquatic and terrestrial ecosystems. The growing body of evidence underscores the importance of cautious handling, stringent safety protocols, and ongoing monitoring of both environmental and human exposure to ensure optimal protection.

These considerations underscore the importance of thorough testing to ensure that even biodegradable and renewable solutions prioritize both human health and environmental safety. Even though PFAS-free alternatives represent an advancement, they remind us that no solution is without trade-offs. Careful evaluation and ongoing research are essential to guarantee that the chosen paths avoid repeating past mistakes.

Jonathan Sharp is chief financial officer at Environmental Litigation Group, P.C. Headquartered in Birmingham, Ala., the law firm offers assistance to civilian and military firefighters affected by toxic exposure. Sharp is responsible for case evaluation, managing firm assets, and conducting financial analysis.