EU Guide for Transitioning to Fluorine-Free Firefighting Foams (F3)
ECHA has recently published a guideline to support stakeholders in transitioning from PFAS-containing firefighting foams to fluorine-free alternatives, in alignment with current and evolving regulations under the POP and REACH frameworks. This includes the anticipated PFAS restriction for foams, expected to be decided during autumn 2025. The guide consolidates best practices, technical challenges, and feasible solutions to support regulatory compliance. It addresses legal obligations related to PFAS content, as well as waste classification and handling. In this context, not only the foam itself but also highly contaminated wastewater must be considered. Furthermore, the document provides detailed information on PFAS detection and mitigation methods, along with environmentally sound disposal strategies. The guidance is intended for both operators and regulatory authorities, particularly those involved in system cleaning and compliance inspections.
Chemical Analysis
The analytical determination of PFAS in legacy foams, replacement foams, and during verification of cleaning procedures is central to all transition and compliance efforts. “Single substance analysis” (also commonly referred to as “target analysis”) using LC-MS/MS is recommended as a highly sensitive method for detecting individual PFAS compounds. This technique is effective for quantifying known PFAS in water and foam samples and can be used for compliance testing under the POP and REACH regulations. However, target analysis may not detect many so-called precursor compounds likely present in firefighting foams. To address this limitation, the Total Oxidisable Precursor assay (TOP or TOPA) can be employed to convert precursor compounds into measurable perfluorinated carboxylic acids (PFCA), providing insight into hidden PFAS contamination. Complementary methods such as Total Organic Fluorine (TOF), Adsorbable Organic Fluorine (AOF), and Extractable Organic Fluorine (EOF) offer broader assessments of fluorine content but do not yield structural information required for POP and REACH compliance testing.
Surface Wiping
The guide recommends swabbing with specialized adsorbent wipes to detect residual PFAS contamination on system components post-cleaning. These wipes are used to sample surfaces such as pipe interiors, fittings, and storage tanks, and are subsequently analyzed to determine PFAS load per unit area. This data can be used to estimate the total PFAS burden remaining in the system. The use of wipes is particularly valuable when visual inspection or water testing alone may not reveal hidden contamination.
Eurofins Analytical Offer
Eurofins has been analyzing fire-fighting foam since 2017, utilizing both target (“single substance”) analysis and the TOP assay. Two specific packages are available for this matrix: PFAS18, which includes regulated PFAS (PFOS, PFHxS, PFOA, PFHxA, etc.) along with other common substances, and PFAS45, which covers additional “simple” precursors as well as 6:2 FTAB and DPOSA. Our TOP package includes the same 18 compounds as the target package, and a combined PFAS18 combo pack (target + TOP) has been introduced for simplified ordering. See links to homepage and product sheet below. In addition, TOF can be determined, contact us for more information. Eurofins also offers a “triple wipe” method for surface swabbing. Recently, we published a white paper demonstrating its performance in recovering PFAS from firefighting foam on stainless steel surfaces (see link below).
Links
EU/ECHA guide
Restriction proposal PFAS in foam
Eurofins (PFAS in foam)
Product sheets (foam and wipes)
White paper (PFAS wipes)
For inquiries regarding PFAS or to order sampling kits, please contact us: