AFFF PFAS Cleanup, Claims, Compliance

AFFF stands for aqueous film-forming foam. It is the slick, fast-spreading fire suppressant historically used for Class B fires involving flammable liquids. The performance kick came from PFAS compounds inside the foam. PFAS are a large family of fluorinated chemicals sometimes called forever chemicals because they do not break down easily in the environment.

That chemical stubbornness made foam incredibly effective, and it also created a long tail of liability. PFAS can migrate into soil and water, stick to surfaces, and persist in drainage systems. When AFFF concentrates or diluted foam end up outside of approved containment, you are treating more than a slippery floor. You are treating a hazardous substance release with reporting obligations in many jurisdictions.

PFAS can accumulate in people and wildlife. Health studies link exposures to certain PFAS with increased cancer risk, immune effects, thyroid issues, and liver or kidney impacts. The stuff spreads easily in water and does not politely stay where you put it. That makes storm drains, sumps, and unprotected soils high-priority areas after a discharge.

There is also a regulatory hammer. The United States Environmental Protection Agency now lists PFOA and PFOS as hazardous substances under federal Superfund law. That triggers reporting and cleanup duties when threshold quantities are released. Many states also treat any AFFF discharge as a reportable spill with strict timelines. Property managers are often the ones stuck between the incident and the inbox, so a smart response plan is as valuable as the best shop vac on the market.

You do not need to be a lawyer to manage an AFFF incident, but you do need a working map of obligations.

- Federal: EPA has designated PFOA and PFOS as hazardous substances under CERCLA. That means releases above reportable quantities may require notification to the National Response Center and state authorities, plus cleanup consistent with federal standards. EPA and OSHA guidance also sets expectations for worker protection, hazard communication, and disposal.

- Military and federal procurement: The National Defense Authorization Act phases out PFAS foam purchases for Department of Defense sites by October 1, 2023 and sets a stop-use date of October 1, 2026, with narrow exceptions. Even if you are not on a base, these dates shape the market and expectations for alternatives.

- State laws: Many states have moved faster than federal rules on foam. Colorado requires containment measures for PFAS foams, bans most training uses, and requires reporting discharges within 24 hours. Maine, California, New York, and others have banned certain sales, required manufacturer notices, or restricted testing uses. Most states require rapid notification to a spill hotline when any AFFF is discharged.

- Local and utility rules: Some sewer districts prohibit PFAS-laden discharges to publicly owned treatment works without preapproval or pretreatment such as granular activated carbon.

When in doubt, treat AFFF runoff as regulated waste, preserve samples, and call the state spill line within 24 hours. Fast, transparent reporting beats slow silence every time.

You are dealing with a fire suppressant that loves to travel with water, so containment is the day-one mission.

- Stop the source. If a foam system is still feeding, isolate it. Lockout-tagout applies.

- Control migration. Close floor drains, place drain covers, build simple berms with absorbent socks, and route flow to a contained sump. Protect door thresholds and elevator pits. Foam in a pit is much easier than foam in a creek.

- Keep people off it. Post the area and restrict entry. PFAS risk aside, foam is a slip hazard that turns a spill into an injury claim.

- Suit up. OSHA-level PPE protocols apply here. At minimum, use chemical-resistant gloves such as nitrile, splash goggles or face shield, and waterproof boots. For agitation or spray work, add Tyvek or similar splash protection and an appropriate respirator based on air monitoring and your written program.

- Do not hose it to the parking lot. Water moves PFAS farther. If you must rinse to collect, make sure the rinse path is into a lined or contained area with a plan to pump and treat.

- Document from minute one. Log the time of discharge, suspected product, concentration if known, who discovered it, photos of affected areas, and any immediate control steps. Keep the original Safety Data Sheet for the foam on the incident file.

- Consider quick screening. If you genuinely do not know whether the installed foam contains PFAS, collect a small sample and send for PFAS analysis. Many legacy systems still do. We typically treat unknowns as PFAS-positive until proven otherwise.

PFAS cleanup is not glamorous, but it is judged. Regulators, insurers, and sometimes plaintiff attorneys will all look at how you handled it. The goal is practical cleanup that resists second-guessing.

- Start with source removal. Pump standing foam and liquid into closed, labeled containers. Use sorbent pads that are compatible with PFAS events and avoid products that simply emulsify and spread the problem. Keep vacuum exhausts filtered and contained to avoid aerosolizing residues.

- Clean surfaces with capture. Use low-foaming detergents, warm water where appropriate, and physical agitation that is strong enough to lift residues but gentle enough to avoid splatter. Always control rinse water. For rough concrete, expect more time and perhaps multiple passes to pull residues out of pores.

- Protect your drains during cleaning. Keep drain covers in place until you are ready to pump collected liquid to storage or treatment.

- HVAC and porous materials. If foam reached air intakes, evaluate filters, coils, and ductwork. In our experience, soft goods such as ceiling tiles, insulation, and acoustic panels exposed to foam are usually removed and disposed as contaminated materials rather than cleaned in place.

- Soils and exterior areas. AFFF that escaped indoors often heads outdoors. If exterior discharge occurred, coordinate with an environmental consultant for soil and groundwater sampling. Early data prevents later surprises. In high-risk cases, we set up portable carbon treatment to polish contact water before any discharge per permit.

- Verification sampling. Wipe samples of cleaned surfaces and analysis of collected wastewater provide the data you need to close a file. Labs commonly use EPA Method 537.1 or 533 for drinking water and Method 1633 for non-potable water and solids. Keep all chain-of-custody documents.

- Triad’s method. Our teams follow a respond-and-stabilize model first, then remediate-and-clean, then rebuild-and-finish. For AFFF, that translates to immediate containment, controlled decontamination, defensible disposal, and clear documentation at each handoff.

You cannot clean properly if you do not dispose properly. Foam concentrates, mixed foam-water, saturated pads, PPE, removed building materials, and spent filters are regulated wastes.

- Classification. Federal hazardous waste rules do not list PFAS as a RCRA hazardous waste at the time of writing, but PFOA and PFOS are hazardous substances under CERCLA and many states regulate PFAS wastes tightly. Some states label AFFF wastes as hazardous or special waste by rule. When in doubt, manage as hazardous and confirm with your state agency.

- Transportation. Use licensed hazardous waste haulers, UN-rated containers, and proper labels. Most clients want a full manifest trail from pickup to final disposition. Do not mix AFFF waste with other streams without approval.

- Treatment and disposal. Options include high-temperature incineration at approved facilities, solidification and disposal in permitted landfills that accept PFAS wastes, and on-site or off-site liquid treatment using granular activated carbon or ion exchange before discharge to a sewer with permission. Local prohibitions often apply to direct sewering of PFAS liquids.

- Records you keep forever. Keep manifests, certificates of destruction, weight tickets, and any approvals from regulators or utilities. Those are the documents that stop questions later.

AFFF events live in the gray area between property claims and pollution exclusions. Coverage depends on your policies and the facts. Here is how to protect your position.

- Check the right policies. Property, business interruption, general liability, contractors pollution liability, site pollution liability, and specialty environmental policies may all be relevant. Public entities often have pool coverage with special terms. Some property policies exclude pollution unless caused by a covered peril such as fire. Others provide limited time-element pollution coverage.

- Notify early and factually. Report the incident promptly to your carrier or broker. Stick to facts, not guesses. If lab results are pending, say so.

- Build a bulletproof file. We include incident reports, time-stamped photos, video of the area and drains, SDS for the foam, sample plans and lab reports, PPE logs, air or meter readings if taken, daily field notes, scope and pricing with line-item transparency, regulator notifications and correspondence, and all disposal documentation.

- Expect questions on cause and spread. Be ready to explain what triggered the discharge, whether training or testing was involved, how much foam was released, how far it traveled, and how you prevented further migration.

- Cost control that still meets standards. Insurers want reasonable, necessary, and customary. Regulators want protective and documented. Our secret sauce is sequencing. We do not over-clean early areas before later areas are contained, and we confirm with targeted sampling to end work where the data says to end it.

The only cleanup more affordable than a well-run response is the spill that never happened. You do not have to rebuild your building to lower the odds.

- Know what foam you have. Inventory all foam concentrates, tank labels, and SDS. If the product is legacy and unlabeled, test it for PFAS content.

- Replace where you can. Many facilities can switch to fluorine-free foams that meet current fire codes and local approvals. Work with your fire protection vendor and AHJ before swapping. Keep replacement certificates and disposal records for the old stock.

- Engineer for containment. Install or test drain shutoffs, keep drain covers staged, maintain curbing around storage and test areas, and consider a lined test pit for any required system testing.

- Write the plan and train it. A simple two-page AFFF spill plan goes a long way. Who shuts off what, who calls whom, where the drain covers live, which doors to block, and how to document from minute zero. Practice it quarterly.

- Coordinate with your fire department. Share your plan and ask about their foam choices. Many departments have already moved to fluorine-free foams for training and response, and they will appreciate clear site maps and containment ideas.

- Maintain your system. Misfires happen when valves stick and sensors fail. Regular inspection and testing by a licensed fire protection contractor, with records retained, reduces unpleasant surprises at 2 a.m.

High-rise garage system discharge

A malfunctioning detection head pops a foam system in a subgrade garage. Foam blankets the floor and starts creeping into trench drains.

Our sequence: Isolate the riser and stop the feed. Drop drain covers and pack absorbent socks along trench edges. Pump standing foam to totes. Wet-wash in sections toward a temporary berm, then pump to a vacuum truck. Pull grate covers, clean the trench, and bag solids. Sample the collected liquid and the trench wipe. Arrange carbon treatment for the liquid before sewer discharge with utility approval. Notify the state spill line within hours and follow with an email log and SDS. Carrier gets a clean package with before-and-after photos, waste weights, and lab results.

Airport hangar test gone wrong

A contractor triggers a full deluge during a function test without containment measures in place. Foam escapes a door and reaches a rain line.

Our sequence: Call in additional containment materials, block exterior storm grates with covers and sandbags, and collect exterior foam into a lined pit. Bring in an environmental consultant for soil sampling along the flow path. Pump all collected liquids to a treatment system with carbon polishing. Remove the top few inches of impacted soil near the storm line as directed by the consultant. Report to the state within the same day with an initial map and plan. Document contractor involvement and system settings for the claim file.

Warehouse spill during drum movement

A pallet jack spears a drum of AFFF concentrate in a chemical storage room. A quart or two hits the floor.

Our sequence: This one is smaller but still regulated in many states. Stop the release, apply compatible absorbents, and place waste in a closed drum with a proper label. Decon the floor with controlled rinsing to a portable containment tray. No drains are involved, so no utility notifications. Sample the rinsate for PFAS. Notify the state spill line if your state requires reporting of any AFFF discharge, which many do. File the incident report with photos, SDS, and disposal receipt.

The fastest way to turn a controllable event into a long problem is to skip reporting or skip records. Build your checklist now and follow it every time.

- Who you might notify: Your state environmental agency spill hotline, local health department, sewer district or publicly owned treatment works if any discharge to sewer is proposed, property insurer or risk pool, and sometimes the National Response Center if federal reportable quantities are met. Airports and ports may have additional reporting triggers.

- When to notify: Many states require 24-hour reporting for any AFFF discharge, even during actual fires. If you are in a state with specific PFAS foam rules, expect same-day or next-day deadlines. Federal CERCLA notifications kick in when hazardous substance reportable quantities are released. If you are unsure, call the state hotline and document the advice you are given.

- What to save: Incident narrative with timestamps, photos and videos, SDS, product labels, sampling plan, chain of custody forms, lab reports, containment sketches, disposal manifests, certificates of destruction or treatment, utility approvals, regulator emails and letters, and a final after-action report summarizing what was done and why. Keep it all in one file that your insurer, counsel, or regulator can read without a scavenger hunt.

- How to speak regulator. Be prompt, be complete, and be specific. “We placed drain covers on the two north trench drains at 10:05 a.m.” is better than “We contained the area.” If a question comes in that you cannot answer, say you will follow up with data and do it.

No. Many modern foams are fluorine-free. Legacy AFFF and some film-forming foams still contain PFAS. If you did not purchase it in the last few years with a clear fluorine-free label and documentation, test it or assume it is PFAS-containing.

Often yes. Many states require reporting of any AFFF discharge within 24 hours. Federal reporting can also apply if threshold quantities of hazardous substances are released. Check your state rules and your site permits.

Not without approval. Many sewer districts prohibit PFAS-laden discharges. If discharge is allowed, pretreatment such as activated carbon is usually required and you must document it.

For drinking water, labs use EPA Methods 537.1 or 533. For non-potable water, wastewater, and solids, labs use EPA Method 1633. Ask for a PFAS target list that includes PFOA and PFOS at a minimum.

Treat AFFF discharges like a regulated hazardous cleanup. Without training, PPE, containment gear, and a disposal plan, a well-meaning crew can spread contamination and create liability. Bring in a restoration team that follows IICRC, EPA, OSHA, and your state environmental agency protocols.

Sometimes. Pollution exclusions can bite, but many insureds have endorsements, time-element pollution coverage, or separate environmental policies. Solid documentation and a clear causal story make approvals far more likely.

Because PFAS cleanup is mostly about control, capture, and proof. Our crews are set up for regulated materials, we already use licensed haulers and approved facilities, and our documentation is built for both regulators and claims examiners. The same playbook we use for biohazards and crime scenes translates well here: strict protocols, careful handling, and airtight records.

Triad technicians are trained to follow IICRC cleaning standards, OSHA worker protection rules, and environmental guidance from EPA and the Texas Commission on Environmental Quality, along with your state’s equivalent agency. For AFFF events, we show up with containment gear, sorbents, drain protection, and sampling kits. We stabilize first, then remove and decontaminate, then dispose and document. Our claim support team assembles the file as work progresses so you do not spend your nights begging four vendors for a missing manifest.

If you manage facilities with legacy foam systems, we can help you inventory, test, and plan for substitutions, and we can coordinate disposal of old stock with licensed providers. If you just had a spill, we can help you stop the spread, meet your reporting deadlines, and finish with the kind of documentation that closes cases rather than opening new ones.